American Rescue Plan Act of 2021

As part of the American Rescue Plan Act of 2021 (“ARPA”), Congress enacted a temporary Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) subsidy for certain individuals for coverage periods from April 1, 2021 to September 30, 2021 (the “Subsidy Period”).  On April 7, 2021 the United States Department of Labor (“DOL”) issued FAQs to