Pinpointing COBRA responsibility during a business reorganization requires careful advanced consideration of numerous fact-specific elements.(Photo: Shutterstock)

The American Rescue Plan Act's (ARPA) federally funded, 100 percent "free" COBRA subsidy has generated much attention — and perhaps even more questions. Fortunately, although we still await further federal agency guidance to resolve lingering concerns, we can sort out many questions with already available published material. One such issue relates to subsidy responsibilities that surface in conjunction with a business reorganization.

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