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IRS Provides Guidance on COBRA Election and Payment Deadlines
McDermott Will & EmeryLink to more items from this source
[Guidance Overview]
Oct. 27, 2021

"[A] plan may not require a qualified beneficiary to make an initial COBRA premium payment before November 1, 2021, as long as the payment is made within one year and 45 days of the individual's COBRA election.... [F]or periods not covered by the initial COBRA premium payment ... [Notice 2021-58] indicates that the payments are due one year from the date that the payment originally would have been due, taking into account the normal 30-day grace period."

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