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IRS Answers ARPA COBRA Subsidy Questions
VorysLink to more items from this source
[Guidance Overview]
May 26, 2021

"If an AEI's COBRA qualifying event was before April 1, 2021, ... the plan sponsor must make subsidized COBRA available starting as of April 1, 2021, [but] the IRS has now told us that an AEI has the option to waive subsidized COBRA for the period between April 1, 2021 and his or her actual election.... [T]he DOL model Extended Election Notice does not address or include any election mechanism for an AEI's option to waive COBRA coverage for the period between April 1, 2021 and an AEI's actual election."

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