News & Analysis as of

Health Insurance Department of Labor (DOL) Consolidated Omnibus Budget Reconciliation Act

McDermott Will & Emery

Takeaways from a Recent COBRA Notice Class Action Settlement

Recent years have seen a barrage of class action lawsuits alleging that group health plan continuation coverage election notices, required under the Consolidated Omnibus Budget Reconciliation Act (COBRA), are deficient in one...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

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

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

Foley & Lardner LLP

Benefits Issues That Arise Upon Misclassification of Employees

Foley & Lardner LLP on

Worker classification is an area of major concern for employers of all sizes. Misclassification of workers as independent contractors has labor and employment ramifications as well as employee benefits ramifications. Guidance...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

Epstein Becker & Green

May 31, 2021 Deadline Approaching for ARPA’s COBRA Subsidy Election Notices

Epstein Becker & Green on

As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”), a $1.9 trillion COVID-19 relief package, into law on March 11, 2021, which, among other things, mandates that employers provide 100...more

Brownstein Hyatt Farber Schreck

What Is An Involuntary Termination Or Reduction In Hours For ARPA COBRA Premium Assistance?

One of the first questions that must be addressed in order to determine whether an individual is eligible for the temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes)...more

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

COBRA Subsidy: You’ve Got Questions...We’ve Got Answers

The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it...more

Vinson & Elkins LLP

DOL Releases Temporary COBRA Subsidy Guidance For Employers

Vinson & Elkins LLP on

The Department of Labor (“DOL”) issued new guidance earlier this month on the temporary COBRA subsidies provided by the recently enacted American Rescue Plan Act (the “ARP”), which employers may find useful in administering...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

Brooks Pierce

Availability of Health Insurance Subsidy Requires Employers to Act

Brooks Pierce on

On March 11, 2021, President Biden signed the American Rescue Plan Act (“ARPA” or the “Act”), another piece of the federal government’s response to the COVID-19 pandemic. Among other things, the Act provides premium...more

Parker Poe Adams & Bernstein LLP

U.S. Labor Department Answers Some - But Not All - Key Questions About New COBRA Subsidies

As previously reported in EmployNews, the American Rescue Plan Act provides “assistance eligible individuals” with the option to receive fully-subsidized COBRA coverage from April 1, 2021 through September 30, 2021....more

Fox Rothschild LLP

Department Of Labor Issues Guidance, Model Notices For COBRA Premium Subsidies Under The American Rescue Plan Act

Fox Rothschild LLP on

On April 7, 2021, the U.S. Department of Labor (DOL) issued much needed guidance to employers and their COBRA administrators on the “COBRA premium subsidy” provision of the American Rescue Plan Act (ARPA). This provision...more

Miles & Stockbridge P.C.

Part III: DOL Releases Model Notices for Mandatory COBRA Premium Subsidy

Under the American Rescue Plan Act of 2021 (ARPA), which was passed by Congress on March 11, 2021, the cost of health insurance coverage pursuant to the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) is...more

Holland & Knight LLP

DOL Releases Guidance and Model Notices for New COBRA Premium Subsidy

Holland & Knight LLP on

A COBRA subsidy program was enacted in March 2021 under the American Rescue Plan Act (ARPA). On April 7, 2021, the U.S. Department of Labor (DOL) released guidance and model notices on an information…...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

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

COBRA Subsidy: What We Know Now After Initial DOL Guidance

Less than a month after the American Rescue Plan Act of 2021 (ARPA) was signed into law, new U.S. Department of Labor (DOL) guidance and model forms are clearing up a number of employer concerns about the 100 percent COBRA...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

FordHarrison

DOL Publishes FAQ Guidance and Model Notices Regarding the COBRA Subsidy Available Under the American Rescue Plan Act

FordHarrison on

The American Rescue Plan Act (ARPA), signed into law on March 11, 2021, requires employers to provide subsidized COBRA coverage to employees (and family members) who qualify for COBRA due to an involuntary termination of...more

BCLP

BCLP Benefits Newsletter: Q1 2021

BCLP on

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 involuntary termination of employment or a...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

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