Employers in the U.S. should remember that they may be required to pay for employees' COBRA coverage this year. The American Rescue Plan Act of 2021 provides that, for periods of COBRA coverage between April 1 and September 30, 2021, that were triggered by an involuntary termination of employment or a reduction of hours, 100% of the COBRA premium will be paid by the employer, health plan, or insurer, and the premium expense will be reimbursed by the federal government through a refundable FICA tax credit.
For more information, see the helpful blog post by our colleagues in the Employee Benefits and Executive Compensation group, which can be found here: DOL Flies Alone: Guidance on the 100% COBRA Subsidy under the American Rescue Plan Act of 2021.
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