Clarifying Guidance on COBRA Deadline Extension Relief

Notice 2021-58 clarifies that the disregarded periods to elect COBRA coverage and make initial and subsequent COBRA premium payments generally run concurrently. The guidance provides the following rules to illustrate the applicable time frames:

• If an individual elected COBRA coverage within the initial 60-day COBRA election time frame will have one year and 45 days after the date of the election to make their initial COBRA premium payment.

• If an individual elected COBRA coverage outside of the initial 60- day COBRA election time frame, they generally will have one year and 105 days after the date the COBRA notice was provided to make the initial COBRA premium payment (subject to transition relief).

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