On May 18, the IRS released Notice 2021-31. The notice contains detailed guidance on subsidies employers must provide COBRA beneficiaries pursuant to the American Rescue Plan Act (“ARP”), and uses a Q&A format to illustrate several specific examples and potential issues regarding the subsidies. For employers, one of the many issues of interest addressed in this notice is the determination of which employee departures qualify as involuntary terminations triggering COBRA assistance.… Continue Reading