Multiemployer Alert: The American Rescue Plan Act of 2021 – Federal COBRA Subsidy

This Multiemployer Alert provides information regarding the federal COBRA subsidy and its potential effects on plan sponsors and participants. The American Rescue Plan Act of 2021 (ARPA), signed into law on March 11, 2021, is a $1.9 trillion stimulus package, meant to provide economic aid in response to the global coronavirus pandemic. The alert covers eligibility and general terms, information on the election period extension, and the notice requirements for plan sponsors and participants. The alert also notes how the COBRA subsidy is a refundable tax credit against payroll taxes.