In Notice 2021-58, the Internal Revenue Service clarified that the one-year tolling relief periods for Consolidated Omnibus Budget Reconciliation Act (COBRA) elections and initial premium payments run concurrently, not consecutively. This means that a qualified beneficiary generally will have only one year of total disregarded time for the election and initial payment periods.
IRS Provides Further Guidance on COBRA Election and Payment Deadlines
By Sarah Raaii and McDermott Will & Emery on October 27, 2021