The American Rescue Plan Act of 2021 (ARPA), among other significant items, imposed new obligations for employers pursuant to the Consolidated Omnibus Reconciliation Act (COBRA). Specifically, ARPA requires employers to provide COBRA premium subsidies to certain employees from April 1, 2020, through Sept. 30, 2021. The requirement comes with complicating definitions, retroactivity provisions, and new forms, creating a temporary compliance issue for employers. On April 7, the U.S. Department of Labor issued model notices and "FAQ's" to assist with these compliance issues.