On March 11, 2021, the American Rescue Plan Act of 2021 (ARP) was passed and signed into law. ARP has significant and immediate impacts on employee benefit plans, employers, and other plan sponsors and plan administrators. On April 7, 2021, the United States Department of Labor (DOL) issued much anticipated guidance and model forms under the COBRA subsidy rules provided by ARP. The FAQ guidance and forms clarify some issues that employers have raised about the COBRA subsidy provisions of the ARP, but leave a number of the most significant questions unanswered. Review our full alert about the DOL’s guidance here.