Importantly, small employers are not required to "look back" to past terminations or reductions of hours the way employers with 20 or more employees are required to do.

Benefits brokers who consult with plan administrators of employer-sponsored group health plans, will need to ready clients for the multiple phases that will follow receipt of qualified beneficiaries' American Rescue Plan Act ("ARPA") subsidy elections, which will start rolling in during the next month. Not since 2009 has a plan administrator had such an active role to plan in the administration of COBRA.

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