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|All Good Subsidies Must Come to an End: ARPA's COBRA Subsidy Expiration Notice Requirements|
Apr. 21, 2021
"Plan administrators must notify [assistance eligible individuals (AEIs)] at least 15 days (but no more than 45 days) before they will lose the subsidy.... This deadline creates an immediate problem with respect to AEIs [already] nearing the end of their maximum COBRA coverage period."
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