01
Jun
Who Needs to Know
Employers.
Why It Matters
On March 25 and April 15, Troutman Pepper reported on the 100% federally funded COBRA premium subsidy included in the American Rescue Plan Act (ARPA), noting the need for additional guidance on a number of issues. On May 18, the Internal Revenue Service (IRS) issued Notice 2021-31, in the form of 86 FAQs, providing much needed guidance on the implementation and administration of the COBRA premium subsidy and refundable premium assistance tax credit.
On March...