On June 24, 2022, the Supreme Court of the United States (the “Court”) issued its opinion in Dobbs v. Jackson Women’s Health Organization, overturning the long-standing precedent of Roe v. Wade. In its 6-3 decision, the Court...more
On May 18, 2021, the Internal Revenue Service (“IRS”) published Notice 2021-31 (the “IRS Notice”) containing detailed guidance relating to premium assistance for COBRA benefits under the American Rescue Plan Act of 2021...more
The American Rescue Plan Act (“ARPA”) became law in March of this year. One of the many relief provisions included in ARPA is a temporary subsidy of COBRA continuation premiums for certain individuals, summarized in our...more
On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”) which is another coronavirus stimulus package aimed at speeding up the United States’ recovery from the economic and health...more
The Internal Revenue Service (“IRS”) recently issued Notice 2020-29 and Notice 2020-33 which allow employers to provide various new types of relief to employees participating in Section 125 cafeteria plans (including flexible...more
The Departments of Labor, Health and Human Services and Treasury (the “Agencies”) recently released final regulations1 that create new opportunities for employers to provide health reimbursement arrangements (“HRAs”) to...more
After several rounds of additional review and a three-month delay in the effective date, the final regulations originally issued by the U.S. Department of Labor (the “DOL”) in December 2016, which established new requirements...more
As the federal agencies continue to issue more guidance on the application of various provisions of the Affordable Care Act (the “ACA”) to employer-sponsored health coverage, there are some recent developments that we want to...more
Under so-called “employer payment plans” (“EPPs”), an employer pays or reimburses an employee for substantiated premium costs under individual health plan insurance coverage (i.e., nonemployer individual health plan...more
In This Alert:
- A. What Is The Employer Shared Responsibility Penalty?
- What Is The “Failure To Offer Coverage Penalty”?
- How Is The “Failure To Offer Coverage Penalty” Calculated?
- What Is...more