EP 103: IRS Guidance on ARPA COBRA Subsidies—Employer Takeaways

In this episode, Chase Cannon and Suzanne Spradley discuss the recently published IRS FAQ guidance on ARPA COBRA premium subsidies. Chase gives an overview of six steps employers need to take to ensure compliance. Chase and Suzanne discuss IRS FAQs addressing what constitutes a reduction in hours or involuntary termination, including employment contract and severance situations. Chase outlines the IRS guidance on employer involvement in claiming the tax credit, including documentation and substantiation issues. The two close with thoughts on the overall process for employers.