Consolidated Omnibus Budget Reconciliation Act (COBRA) – Federal Employment Law (FEL) Practice Test

The key idea is that the statute separates certain sanctions from taxes and standard civil penalties by explicitly naming them as their own remedy. In this context, attorney's fees are listed as a penalty distinct from the daily excise tax and civil penalties, meaning the court can order payment of legal costs as a separate sanction. This reflects how enforcement can include not just fines but also compensation for the legal assistance required to pursue the matter. The other options don’t function as penalties: tax credits reduce liability rather than punish noncompliance, grant programs are funding or incentives, and penalty exemptions remove penalties rather than add them. So attorney's fees are the explicit separate penalty described.