News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Deadlines Employee Benefits

Woods Rogers

Does the Fun Ever Stop? COVID-19 Tolling Ends for COBRA Deadlines

Woods Rogers on

On April 10, 2023, President Biden signed legislation to end the COVID-19 national emergency effective immediately, including ending the requirement to extend COBRA deadlines due to the COVID-19 pandemic. Plan administrators...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Deadline Tolling

McDermott Will & Emery on

The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April...more

Bradley Arant Boult Cummings LLP

The End of the COVID-19 Public Health Emergency: Federal Agencies Clarify Coverage Implications for Group Health Plans

With the COVID-19 Public Health Emergency (PHE) set to end on May 11, 2023, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the “departments”) have published FAQs explaining...more

Bradley Arant Boult Cummings LLP

The End of the COVID-19 Public Health Emergency: New Deadlines for Group Health Plans

With the COVID-19 Public Health Emergency (PHE) set to end on May 11, 2023, federal agencies have published FAQs explaining how the end of the PHE will affect previously extended deadlines relating to COBRA, HIPAA special...more

Bass, Berry & Sims PLC

Tolling, Tolling, Tolling, Keep Those COVID-19 National Emergency Deadlines Tolling

On February 18, President Biden announced that the COVID-19 National Emergency would continue beyond March 1, 2022, for up to another year. As a result of the continuing National Emergency, the “tolling” of several important...more

McDermott Will & Emery

IRS Provides New Guidance on COBRA Election and Payment Deadlines

McDermott Will & Emery on

In Notice 2021-58 (the Notice), the Internal Revenue Service (IRS) clarified that the one-year tolling relief periods for Consolidated Omnibus Budget Reconciliation Act (COBRA) elections and initial premium payments run...more

Laner Muchin, Ltd.

Reminder: Employers Have Until September 15 to Issue COBRA Subsidy Termination Notices

Laner Muchin, Ltd. on

As previously reported, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA payments for a COBRA qualified beneficiary who becomes eligible for COBRA due to a reduction in hours or involuntary...more

Fisher Phillips

September 15 Deadline Looming for Required ARPA Notices

Fisher Phillips on

The American Rescue Plan Act of 2021 (ARPA) mandates that group health plans that are subject to COBRA must provide coverage to certain assistance eligible individuals (AEI) at no cost for periods of coverage between April 1,...more

Sheppard Mullin Richter & Hampton LLP

ARPA COBRA Subsidy Expiration Notice Due by September 15

The American Rescue Plan Act (“ARPA”) requires the full cost of COBRA premiums to be subsidized for COBRA continuation coverage during the period from April 1, 2021 through September 30, 2021 (“Subsidy Period”) of certain...more

Ballard Spahr LLP

Reminder: COBRA Notice Deadline is May 31

Ballard Spahr LLP on

This is a reminder that a COBRA notice deadline is approaching. It applies to employers that are subject to the federal COBRA rules....more

Carlton Fields

COBRA Deadlines and Proofs of Mailing in Carter v. Southwest Airlines Co. Board of Trustees

Carlton Fields on

Carlton Fields tax attorney Lowell Walters explains what we can learn about a recent case in which a former employee claimed to be owed benefits, and provides suggestions on how companies can protect themselves. The video...more

Dickinson Wright

May 31, 2021 Notice Deadline Approaching for New COBRA Subsidy Relief

Dickinson Wright on

The American Rescue Plan Act of 2021 (“ARP”) includes a 100% COBRA temporary subsidy for certain eligible individuals (“Assistance Eligible Individuals”) who lost health care coverage due to an involuntary termination of...more

Patterson Belknap Webb & Tyler LLP

DOL Issues Additional Guidance Regarding the Duration of Previously Announced Deadline Extensions

On February 26, 2021, the DOL issued guidance regarding the impact of that statutory limitation on the previously announced deadline extensions, in EBSA Disaster Relief Notice 2021-01. Disaster Relief Notice 2021-01, in...more

Locke Lord LLP

U.S. Department of Labor Clarifies Extension of Certain Employee Benefit Deadlines Due to COVID-19

Locke Lord LLP on

As discussed in our prior blog post, on April 28, 2020, the Employee Benefits Security Administration, U.S. Department of Labor, Internal Revenue Service, and Treasury Department (the “Agencies”) published joint guidance...more

Nelson Mullins Riley & Scarborough LLP

Don’t Restart the Clock Just Yet – COBRA, HIPAA, Other Deadlines Might Be Further Extended!

At the last minute, certain suspended COBRA, HIPAA and claims procedure deadlines that were set to expire on February 28, 2021 have been further extended. As we discussed last year the Department of Labor (DOL) and Internal...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Employee Benefit Plan COVID-19 Deadline Extensions May Expire as Early as February 28

Employers are facing uncertainty as to the expiration of the COVID-19 relief the U.S. Department of Labor (DOL) and Internal Revenue Service (IRS) issued in a joint guidance on May 4, 2020. The joint guidance requires...more

Morgan Lewis - ML Benefits

Suspended Deadlines Under ERISA: Is It Time to Restart the Clock?

As we described in our LawFlash from last spring, the US Department of Labor’s Employee Benefits Security Administration (EBSA) and the Internal Revenue Service (IRS) (collectively, the Agencies) issued EBSA Notice 2020-01...more

Vedder Price

Recent Guidance Regarding Employee Benefit Plans

Vedder Price on

There has been a recent flurry of regulatory guidance issued affecting employee benefit plans. Most of the guidance addresses challenges specifically created by the COVID-19 pandemic, while other guidance is applicable...more

Ballard Spahr LLP

CMS Addresses Extended Deadlines for Benefit Plans

Ballard Spahr LLP on

The Department of Health and Human Services Centers for Medicare & Medicaid Services (CMS) has followed the guidance, jointly issued by the U.S. Departments of Labor and the Treasury, that extends benefits-related deadlines...more

Epstein Becker & Green

DOL Gives Extra Time to Plan Participants and Beneficiaries: Benefits Guidance in the Time of COVID-19

Epstein Becker & Green on

Plan participants and their beneficiaries may now have extra time to exercise some of their rights under the employee benefit plans in which they participate. ...more

Littler

COBRA is Temporarily Social Distancing From its Election and Payment Deadlines

Littler on

The IRS and DOL issued guidance on May 4, 2020 that adds a new level complexity to COBRA administration for employer-sponsored plans.  In short, the relief suspends many key participant deadlines during the so-called...more

Jackson Walker

Coronavirus Recovery and Relief Guidance on Employee Benefit Plans

Jackson Walker on

As employers start to think about asking their employees to return to work, in addition to all of the employment law issues, there are also employee benefit plan considerations. Employers need to consider all their benefit...more

Verrill

IRS and DOL Extend Certain Health & Welfare Benefit Plan-Related Deadlines

Verrill on

This post summarizes the health and welfare benefit plan-related deadline extensions described in IRS Notice 2020-23 issued April 9, 2020 and the DOL and Treasury Joint Notice issued April 28, 2020 (the “Joint Notice”). IRS...more

Robinson & Cole LLP

Joint Agency Guidance Extends COBRA and Other ERISA Deadlines

Robinson & Cole LLP on

On May 4, 2020, the Department of Labor and Department of Treasury (the Departments) issued joint guidance requiring certain COBRA, HIPAA and ERISA deadlines be determined without regard to the “Outbreak Period,” which began...more

Brownstein Hyatt Farber Schreck

For Whom the Timing Tolls: The COVID-19 Outbreak Period Interrupts Benefit Plan Deadlines

New employee benefits guidance temporarily extends certain time frames and deadlines for participant actions and relieves some plan administration compliance obligations during the COVID-19 National Emergency (the “COVID-19...more

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