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ARPA COBRA Subsidy Guidance: IRS Notice 2021-31 and Emergency Relief Notices (PDF)
Jenner & Block 
[Guidance Overview] May 24, 2021 "This alert provides an overview of the reduction in hours and involuntary termination guidance contained in [Notice 2021-31], breaking down the types of terminations or reductions in hours that would give rise to COBRA subsidy eligibility during the subsidy window. This alert also covers the interplay between [the Act, the EBSA and IRS Joint Notice of May 4, 2020, and EBSA Disaster Relief Notice 2021-01]. These aspects of the Notice encompass myriad human resource scenarios that employers encounter on a day-to-day basis." |
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