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All Good Subsidies Must Come to an End: ARPA's COBRA Subsidy Expiration Notice Requirements
ProskauerLink to more items from this source
[Guidance Overview]
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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