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| IRS Issues Additional ARPA COBRA Subsidy Guidance TRI-AD  [Guidance Overview] Aug. 2, 2021 "[In] Notice 2021-46, the IRS has indicated that all individuals who still have a right to enroll in COBRA and/or make COBRA payments between April 1, 2021–September 30, 2021, are eligible for the subsidy, unless eligible for other major group health coverage or Medicare. In other words, they don't need to be currently enrolled in COBRA and making payments. This may require employers to offer these AEIs COBRA coverage and the subsidy if the employer or plan administrator are notified by these individuals of such events." |
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