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COBRA Subsidy Update: DOL Issues Model Notices and FAQs

Added by John C. Hughes in Employment Law on April 16, 2021

The Department of Labor (DOL) has released follow-up guidance to the COBRA subsidy provisions in the American Rescue Plan Act (covered in this recent client alert). The DOL’s guidance can be found at this link. Notably, the guidance provided some clarification on the following:

  • Involuntary terminations
  • Coverage start dates
  • Administrative fees
  • Definition of reduction in hours
  • Ineligibility for having other coverage
  • Excepted benefits
  • State mini-COBRA laws
  • Marketplace enrollment

If you have any questions surrounding the DOL’s guidance, please contact
John C. Hughes at or 208.388.4067 or Fernando Aceves at or 208.388.4858.