News & Analysis as of

Health Insurance Consolidated Omnibus Budget Reconciliation Act Benefit Plan Sponsors

Morgan Lewis - ML Benefits

Managing Welfare Plan Risk: The Fiduciary Committee

Fiduciary committees have long been established in connection with retirement plans to manage the investment, legal compliance, and operational risks that can arise under the Employee Retirement Income Security Act of 1974,...more

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

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

Woodruff Sawyer

Agencies Release Revised Instructions for 2022 Reference Year RxDC Reporting

Woodruff Sawyer on

On March 3, 2023, federal agencies released revised Prescription Drug Data Collection (RxDC) Reporting Instructions applicable to the 2022 reference year. RxDC reporting for the 2022 reference year is due on or before June 1,...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers

The Biden administration has announced its intention 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)....more

Bass, Berry & Sims PLC

2022 ERISA Welfare Plan Automatic Participant Disclosures Checklist

Bass, Berry & Sims PLC on

We recognize that many companies sponsor ERISA welfare benefit plans and are currently undergoing their open enrollment process and issuing related participant communications. To assist with that process, we have prepared an...more

Faegre Drinker Biddle & Reath LLP

Navigating Open Enrollment Notice Requirements

Fall open enrollment is upon us, and plan sponsors and administrators are preparing to provide their employees with the required notices related to their health and welfare plans. Notice and disclosure obligations for health...more

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

Medical Travel Reimbursement Benefits Under the Supreme Court’s New Dobbs Decision

On June 24, 2022, the Supreme Court of the United States issued its highly anticipated decision in Dobbs v. Jackson Women’s Health Organization, No. 19-1392. The Dobbs decision expressly overrules the two key precedents that...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

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

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

BCLP

Employers Required to Pay Premiums for COBRA Continuation Coverage Until At Least September 30, 2021

BCLP on

Employers in the U.S. should remember that they may be required to pay for employees’ COBRA coverage this year. The American Rescue Plan Act of 2021 provides that, for periods of COBRA coverage between April 1 and September...more

Goodwin

American Rescue Plan: How to Navigate New Continuation Coverage Standards for COBRA

Goodwin on

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA” or the “Act”), the latest COVID-19 relief bill, into law. Under ARPA, employers will generally be obligated to advance the cost of...more

Smith Anderson

ARPA COBRA Subsidy's Impact on Employer Health Plans

Smith Anderson on

The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more

BCLP

DOL Flies Alone: Guidance on the 100% COBRA Subsidy under the American Rescue Plan Act of 2021

BCLP on

The American Rescue Plan Act of 2021 (“ARPA”) provides that, for the period from April 1, 2021 until September 30, 2021, if an individual’s Consolidated Omnibus Budget Reconciliation Act (“COBRA”) qualifying event is an...more

Laner Muchin, Ltd.

New DOL Guidance and Model Notices Assist Employers with Their New 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

Williams Mullen

DOL Issues Model Notices and FAQs for COBRA Subsidy

Williams Mullen on

As described in our previous alert, the American Rescue Plan Act of 2021 (the ARPA), provides a full subsidy for COBRA premiums for certain qualified beneficiaries entitled to COBRA continuation coverage from April 1, 2021,...more

Stokes Wagner

Employers Should Begin Planning for COBRA Subsidy

Stokes Wagner on

The American Rescue Plan Act (“ARPA”), signed into law on March 11, 2021, obligates employers to pay COBRA insurance premiums for individuals who suffer job loss. Under the plan, employers receive the subsidy, which they pass...more

Fenwick & West LLP

March 2021 Employment Law Update: New ARPA/COBRA Subsidy, COVID-19-Related Sick Leave Developments and More

Fenwick & West LLP on

New ARPA/COBRA Subsidy - The federal American Rescue Plan Act of 2021 (ARPA) provides for a 100% subsidy of COBRA premiums for six months from April 1, 2021 through September 30, 2021, for individuals (and their covered...more

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

DOL Guidance Clarifies Expiration of COVID-19 Deadline Extension for Employee Benefit Plans

The U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published EBSA Disaster Relief Notice 2021-01 in the nick of time on February 26, 2021. EBSA Disaster Relief Notice 2021-01 was released...more

Holland & Knight LLP

COBRA Premium Subsidy Under the American Rescue Plan Act

Holland & Knight LLP on

The recently signed American Rescue Plan Act (ARPA) will have a major impact during the next six months on employers' obligations and considerations in administering COBRA health insurance benefits. Subtitle F of ARPA –...more

Brownstein Hyatt Farber Schreck

No Fooling Around: New Six-Month COBRA Subsidy Starts April 1, Requires Immediate Action

The American Rescue Plan Act of 2021 (“ARPA”) includes a temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes) to “assistance eligible individuals” (“AEIs”). This...more

Miles & Stockbridge P.C.

Part II: The American Rescue Plan Act Requires Employers to Fully Subsidize COBRA for Six Months

The American Rescue Plan Act of 2021, signed on March 11, 2021, requires employers to fully subsidize COBRA for certain eligible individuals. Eligible individuals consist of employees and their spouses and dependents who lost...more

Miles & Stockbridge P.C.

Part I: American Rescue Plan Act - What Employers Need to Know

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARPA, or the “Act”), which created certain additional benefits for employees about which employers should be aware. Extension of FFRCA...more

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