The IRS has issued a draft Form 7200 for employers to claim an advance payment of the tax credit, but we anticipate that the IRS will also issue a revised Form 941 and additional guidance in the near future. Also, while the FAQs acknowledge that employers will need to look back in time to identify all potential AEIs who may have a second election opportunity ("generally" to October 1, 2019, according to the FAQs), the FAQs do not clarify whether an individual who is entitled to COBRA coverage in April 2021, or beyond, due to a second qualifying event or a disability extension of COBRA coverage, could be an AEI. For example, if an employee was involuntarily terminated in November 2018, and her COBRA coverage began on December 1, 2018, her 18-month maximum coverage period would ordinarily expire on May 31, 2020, and she would not be an AEI.