News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Internal Revenue Service Employer Group Health Plans

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

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

Employers Prepare for Thawing ERISA Deadlines

With the pandemic winding down, deadlines for employee benefit plans governed by the Employee Retirement Income Security Act (ERISA) will be resuming. Two different emergencies affect employer-sponsored group health plans:...more

Faegre Drinker Biddle & Reath LLP

COVID-19 National Emergency Plan Deadline Extensions Set to End This Summer

On January 30, 2023, President Biden announced the Administration’s plan to extend the current declarations of the COVID-19 national emergency and public health emergency (PHE) through May 11, 2023, and end both emergencies...more

Pillsbury - Policyholder Pulse blog

Abortion as an Employee Health Benefit – How to Protect against Potential Liability Post-Dobbs

Amazon. Bank of America. Citigroup. Dick’s Sporting Goods. JP Morgan. Kroger. Meta. Microsoft. Procter & Gamble. Target. Walt Disney Company. These are just a few of what is a growing list of companies that have offered to...more

Foley & Lardner LLP

Key Considerations When Offering Abortion Coverage Under a Group Health Plan

Foley & Lardner LLP on

Not surprisingly, leading up to and in the wake of the U.S. Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization, our employee benefits team has been spending a lot of time helping our clients wade through...more

Snell & Wilmer

Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines

Snell & Wilmer on

The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985...more

Lowenstein Sandler LLP

Navigating the Nuances of the COBRA Subsidy Under the American Rescue Plan Act

Lowenstein Sandler LLP on

Hosts Andrew Graw and Megan Monson discuss the American Rescue Plan Act of 2021 (ARPA) as part of the new (third) COVID-19 stimulus relief bill. The ARPA assists qualifying individuals who lose coverage under an employer’s...more

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

IRS Issues Additional Guidance on the COBRA Subsidy

On July 26, 2021, the Internal Revenue Service (IRS) released Notice 2021-46 to provide additional guidance on the Consolidated Omnibus Budget Reconciliation Act (COBRA) subsidy under the American Rescue Plan Act of 2021...more

Morgan Lewis - ML Benefits

IRS Provides Second Round of FAQs on COBRA Subsidies

As we get closer to the September 30 expiration date of the COBRA premium subsidy provided under the American Rescue Plan Act (ARPA), the IRS has issued a second set of FAQs in Notice 2021-46 (Notice) to supplement its prior...more

Fisher Phillips

IRS Provides Further Clarity to Employers on Stimulus Tax Credits

Fisher Phillips on

The Internal Revenue Service recently released a Notice to further explain its position on certain issues related to the COBRA premium assistance and corresponding tax credits available under the American Rescue Plan Act of...more

Eversheds Sutherland (US) LLP

COBRA subsidy strikes again with IRS guidance in Notice 2021-31

The American Rescue Plan Act (the Act) included certain temporary COBRA subsidy provisions that allow “Assistance Eligible Individuals” (AEIs) to receive COBRA subsidies from April 1, 2021 to September 30, 2021 (the...more

Proskauer - Employee Benefits & Executive...

Calculating the ARP COBRA Premium Subsidy Tax Credit

On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice...more

Patterson Belknap Webb & Tyler LLP

IRS Publishes Detailed Guidance Relating to ARPA COBRA Premium Assistance

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

McDermott Will & Emery

How to Apply the IRS’s COBRA Premium Subsidy Guidance

On May 18, 2021, the Internal Revenue Service (IRS) issued much-anticipated Notice 2021-31 (the Notice) regarding the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy provisions of the American Rescue...more

Dickinson Wright

IRS Guidance on COBRA Subsidy, Part III: Claiming the Premium Assistance Credit

Dickinson Wright on

Under the American Rescue Plan Act of 2021 ("ARPA"), a 100% COBRA subsidy is available to qualified beneficiaries who lose coverage due to an involuntary termination of employment or reduction in hours. The subsidy is...more

Bradley Arant Boult Cummings LLP

IRS Guidance Clarifies “Involuntary Termination” for the COBRA Subsidy

In Notice 2021-31, the Internal Revenue Service (IRS) provides broad guidance in a question-and-answer format on the application of the American Rescue Plan Act of 2021 (ARP) regarding premium assistance under the...more

Proskauer - Employee Benefits & Executive...

Guide to New IRS Guidance on COBRA Premium Subsidy

On May 18, 2021, the IRS released Notice 2021-31, which provides implementation guidance on the COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARP). As discussed in our prior blog posts, ARP...more

Alston & Bird

IRS Provides 86 Answers to 86 Questions About the COBRA Subsidy

Alston & Bird on

Our Employee Benefits & Executive Compensation Group summarizes the IRS’s 86 Q&As about the COBRA premium assistance subsidy and offers takeaways employers can use to guide their path ahead of the May 31 deadline....more

Lowenstein Sandler LLP

IRS Issues COBRA Subsidy Guidance

Lowenstein Sandler LLP on

On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA), which provides temporary premium assistance for health, dental, and vision coverage under the Consolidated Omnibus Budget...more

Dickinson Wright

IRS Guidance on COBRA Subsidy, Part II: Determining Assistance Eligible Individuals and Dealing with the Extended Election Period

Dickinson Wright on

Under the American Rescue Plan Act of 2021 ("ARPA"), a 100% COBRA subsidy is available to qualified beneficiaries who lose coverage due to an involuntary termination of employment or reduction in hours.  The subsidy is...more

Faegre Drinker Biddle & Reath LLP

IRS Guidance on New COBRA Subsidy Clarifies Many Outstanding Questions

On May 18, 2021, the IRS released Notice 2021-31, a lengthy series of FAQs clarifying many aspects of the new COBRA subsidy made available under the American Rescue Plan Act of 2021 (ARPA). The FAQs address many of the issues...more

Jackson Walker

American Rescue Plan Act’s COBRA Premium Assistance – A New Ball Game and New Rules

Jackson Walker on

The Internal Revenue Service has provided additional guidance on the the American Rescue Plan Act’s COBRA premium assistance. Greta Cowart summarizes the top 10 takeaways of Notice 2021-31 specifically related to group health...more

Verrill

ARPA Premium Subsidy: Long-Awaited Details Finally Arrive

Verrill on

The IRS recently issued Notice 2021-31, which provides much sought-after detail regarding the contours and operation of the temporary premium subsidy for COBRA continuation coverage available through the American Rescue Plan...more

Epstein Becker & Green

IRS Guidance on ARPA COBRA Subsidies: 86 Q&As and Counting

Epstein Becker & Green on

As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”) into law on March 11, 2021, which, among other things, mandates that employers provide 100 percent COBRA premium subsidies to eligible...more

Akin Gump Strauss Hauer & Feld LLP

COBRA Premium Subsidy under the American Rescue Plan Act of 2021 and IRS Notice 2021-31

On May 18, 2021, the Internal Revenue Service (IRS) released Notice 2021-31 (the “Notice”) providing guidance in Q&A format on the application of the temporary COBRA premium assistance provisions of the American Rescue Plan...more

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