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Insight COBRA Subsidy Update: DOL Issues Model Notices and FAQs

By John C. Hughes,

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 jhughes@hawleytroxell.com or 208.388.4067 or Fernando Aceves at faceves@hawleytroxell.com or 208.388.4858.

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