News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Relief Measures

Woodruff Sawyer

Compliance Alert: Agencies Issue Guidance on the End of COVID-19 Emergencies

Woodruff Sawyer on

On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to end the COVID-19 national and public health emergencies on May 11, 2023. However, on April 10, 2023, the President...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

Stoel Rives - Health Law Insider®

Is Any Pandemic Relief Still Available for Employee Benefit Plans?

As we approach our third new year since the first reported cases of COVID-19, related relief may seem like old news. Although much of the government-sponsored pandemic relief has expired, there are aspects that remain germane...more

Seyfarth Shaw LLP

Are We There Yet? Emergency Declarations and COVID Relief Are Extended Into 2023

Seyfarth Shaw LLP on

Seyfarth Synopsis: HHS has announced that the COVID-19 Public Health Emergency (PHE) has been extended another 90 days, and will run until January 11, 2023....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

Proskauer - Employee Benefits & Executive...

COBRA Election and Payment Periods: Does One Year of “Tolling” Really Mean One Year?

Remember the DOL/Treasury relief that tolled the COBRA election and payment deadlines for up to one year due to the COVID-19 pandemic (referred to below as “Tolling Relief”)? If you have been wondering whether, under that...more

Pullman & Comley - Labor, Employment and...

COBRA Update: Final COBRA Subsidy Termination Notices Now Due

As mentioned in our prior COBRA update, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA premium payments. The subsidy is available to COBRA qualified beneficiaries who become eligible for COBRA...more

Akerman LLP - HR Defense

Deadline Triggered as COBRA Premium Subsidy Ends

Employers and plans are reminded that they must provide a COBRA subsidy expiration notice no later than September 15, 2021, pursuant to the American Rescue Plan Act of 2021 (ARPA). ARPA had included some new COBRA obligations...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

Stinson LLP

COBRA Premium Assistance Expiration Notice Deadline Approaching

Stinson LLP on

The COBRA premium assistance period, as part of the American Rescue Plan Act, will expire on September 30, 2021. Plans are required to send notices to assistance eligible individuals (AEIs) to inform them about the subsidy's...more

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

It’s Not Over ‘Til It’s Over: The COBRA Premium Subsidy is Ending

As we mentioned in our May 23, 2021, article, the American Rescue Plan Act of 2021 (ARPA) provides a 100 percent premium subsidy for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA)...more

Williams Mullen

COBRA Subsidy Expiration Notice is Due September 15

Williams Mullen on

The American Rescue Plan Act of 2021 (the ARPA), signed into law this spring, included premium relief to certain COBRA-qualified beneficiaries that is set to expire September 30, 2021. ...more

Brownstein Hyatt Farber Schreck

Sept. 15 Is Final Deadline for ARPA COBRA Subsidy Expiration Notices

Section 9501 of the American Rescue Plan Act of 2021 (“ARPA”) requires employers, multiemployer trustees and insurers (collectively, “plan administrators”) to provide a 100% subsidy for COBRA health care continuation coverage...more

Arnall Golden Gregory LLP

AGG Talks: Solving Employers’ Problems - The American Rescue Plan Act’s COBRA Subsidy: What Is It and How Does It Work?

Our podcast series, "AGG Talks: Solving Employers’ Problems," features AGG attorneys discussing challenges they have encountered when assisting clients on business and legal issues related to the employment relationship. HR...more

Proskauer - Employee Benefits & Executive...

All Good Subsidies Must Come to an End, Part II: The IRS Adds Some Nuances

In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice.  This post revisits the topic in light of...more

Stinson - Benefits Notes Blog

IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA

On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the...more

Laner Muchin, Ltd.

New IRS Guidance Offers Employers Direction regarding COBRA Subsidy Obligations

Laner Muchin, Ltd. on

As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more

Burns & Levinson LLP

Cobra Subsidies Employer Obligation To Notify Employees by May

Burns & Levinson LLP on

New federal law (Section 9501 of the American Rescue Plan Act of 2021 – ARP Act, PL 117-2) provides a temporary, full subsidy of some premiums that individuals would have to pay for COBRA coverage following a reduction in...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

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

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

The New IRS COBRA Subsidy Guidance: Key Takeaways for Employers

The American Rescue Plan Act of 2021 (ARPA) implemented a 100 percent COBRA subsidy for certain qualified beneficiaries beginning on April 1, 2021, and ending September 30, 2021. On May 18, 2021, more than a month into the...more

Fisher Phillips

IRS Addresses Lingering Employer Questions Regarding COBRA Premium Assistance and Corresponding Tax Credits under the American...

Fisher Phillips on

The American Rescue Plan Act (ARPA) provides for 100% premium assistance to certain qualified beneficiaries for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) for periods of...more

Morgan Lewis

IRS Issues Guidance Regarding American Rescue Plan Act COBRA Subsidy

Morgan Lewis on

The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more

McNees Wallace & Nurick LLC

Good News and Bad News: The IRS Issues 86 Q&A’s on the ARP COBRA Subsidy

On May 18, 2021, the IRS issued the long- awaited guidance on the COBRA subsidy and premium assistance credit available under the American Rescue Plan Act of 2021 through eighty-six questions and answers....more

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