The COBRA subsidy period (April 1, 2021 – September 30, 2021) has begun and with a number of issues still outstanding, employers have no time to lose when it comes to preparing to administer the COBRA subsidy required by the American Rescue Plan Act (ARPA) enacted on March 11, 2021. While we have received limited guidance from the U.S. Department of Labor (DOL), we still expect and await additional guidance from the DOL and the Internal Revenue Service (IRS). Below are considerations for employers to begin thinking about now, including upcoming notice obligations.