Join the Benefits Compliance team for the fifth installment of our American Rescue Plan Act webinar series. We will address the recent IRS guidance on the ARPA COBRA subsidies. Employers will walk away with an understanding of how this guidance clarifies the rules and what they will need to do to comply with the law.
On May 18, 2021, the IRS published Notice 2021-31, which includes 86 FAQs relating to the ARPA COBRA subsidies (which the IRS refers to as premium assistance) and tax credits. Among other things, the FAQs provide clarifications and examples relating to the meaning of reduction in hours and involuntary termination, the certification and documentation of premium assistance eligibility status, and the process and forms to claim the related tax credits.
Of Significant Importance: Employers may require individuals to provide certification or attestation of their eligibility before treating them as an assistance eligible individual (AEI). Further, in order to claim the payroll tax credit, the employer must retain such certification or attestation.