American Rescue Plan Act (ARPA) COBRA Subsidy Guide
… Reinvestment Act (ARRA). Therefore, we will discuss the guidance that was in place in 2009 in this guide as it’s possible that the agencies will adopt similar guidance for the ARPA COBRA subsidy. Under the 2009 guidance, an involuntary termination meant “a severance from employment due to the independent exercise of the unilateral authority of the employer to terminate the employment, other than due to the employee’s implicit or explicit request, where the employee was willing and able to continue performing services.” Involuntary termination was interpreted broadly under this guidance. The following are all examples of involuntary …
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