Frequently Asked Questions

If an individual was given notice of a layoff but resigns prior, would that be considered a voluntary or involuntary term regarding the subsidy?

There has not been clear guidance on the definition of voluntary vs. involuntary termination. Plan
sponsors must use their best judgment when identifying assistance eligible individuals. If eligibility is in
question, Plan Sponsors may want to take a cautious position and include the individual in the list of
AEIs.

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