News & Analysis as of

Plan Administrators Consolidated Omnibus Budget Reconciliation Act

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

Keating Muething & Klekamp PLL

Benefits Monthly Minute - October 2022

The October Monthly Minute highlights a class action that hinges on deficient COBRA notices, the new 2023 benefit plan limits, and a case that held the benefit plan provisions in effect at the time of a claim denial control....more

BakerHostetler

Don't Forget Your COBRA Subsidy Expiration Notice

BakerHostetler on

COBRA subsidies under the American Rescue Plan Act of 2021 (ARPA) end on Sept. 30, 2021, which means businesses must send expiration notices to former employees and other eligible individuals whose COBRA premiums have been...more

Saul Ewing LLP

Guidance Issued on Implementation of ARPA COBRA Premium Subsidy

Saul Ewing LLP on

Group health continuation coverage under the Consolidated Omnibus Reconciliation Act of 1985 (“COBRA”) permits certain group health coverage to be continued by participants and beneficiaries (“qualified beneficiaries”) when...more

Nelson Mullins Riley & Scarborough LLP

COBRA Subsidies are Revived — Update

The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs or had a reduction in hours (and their family...more

Proskauer - Employee Benefits & Executive...

DOL Releases COBRA Premium Subsidy Model Notices – With a Few Surprises

Immediate Action Required - As discussed in our prior posts, the American Rescue Plan Act of 2021 (“ARP”) requires that plan administrators distribute new COBRA notices advising individuals of their possible rights to a...more

Poyner Spruill LLP

Plan Administrators: (Re)Start Your Timers: Deadlines Extended by COVID Have One-Year Limit

Poyner Spruill LLP on

Notice 2021-01 recently issued by the Employee Benefits Security Administration, provides helpful clarification on relief from certain participant deadlines issued last year.  However, it also provides “suggestions” that plan...more

Davis Wright Tremaine LLP

DOL Extends COBRA and Claims Tolling in the Worst Way

In May 2020, the Department of Labor (DOL) and IRS issued guidance to toll various notices, claims, and election deadlines due to COVID-19, including COBRA elections. Examples in the guidance assumed that the National...more

Williams Mullen

IRS and DOL Grant Plan Administrators Some Relief During Pandemic

Williams Mullen on

The Internal Revenue Service (IRS) and the Department of Labor (DOL) jointly offered extensions and other relief to employee benefit plan administrators that may be struggling to meet various filing, notice, disclosure and...more

Dorsey & Whitney LLP

Don’t Get Bitten by Your COBRA Notices

Dorsey & Whitney LLP on

In a growing wave of class action lawsuits, plaintiffs are targeting employers who have allegedly failed to provide proper notice of health care coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985...more

Laner Muchin, Ltd.

What’s In Your COBRA Notice? The Answer May Lead To A Class Action Lawsuit

Laner Muchin, Ltd. on

As previously reported in the Fast Laner, a number of large employers were hit by a wave of class action lawsuits in 2016 involving claims related to deficient COBRA notices. In the case involving Wal-Mart, a federal judge in...more

Foley & Lardner LLP

Check Your COBRA Notices in Order to Avoid Potential Lawsuits

Foley & Lardner LLP on

Have you thought about your COBRA notices recently? Of course not, because COBRA notices don’t warrant your valuable time. They are just another one of those pesky notices that the law requires you to send. If that was your...more

McNees Wallace & Nurick LLC

Pennsylvania Court Addresses Individual Liability Under COBRA (and How to Avoid it)

With increasing frequency, when employees sue their employer or former employer, they also name individual managers or the company’s owners as defendants in their suit. ...more

Holland & Knight LLP

Summary Plan Descriptions Required for All ERISA Retirement, Health and Welfare Plans

Holland & Knight LLP on

• Administrators of all employee benefit plans subject to the Employee Retirement Income Security Act of 1974 (ERISA) should ensure their plans' compliance with ERISA's Summary Plan Description (SPD) requirement. •...more

Snell & Wilmer

Rethinking COBRA After Health Care Reform

Snell & Wilmer on

The Health Care Reform Act made many changes to health plans, but one thing it did not do was expressly eliminate or change the COBRA rules. Although health care reform does not expressly change COBRA, it does, in many ways,...more

Williams Mullen

New COBRA and CHIP Notices Highlight Affordable Care Act Marketplaces

Williams Mullen on

The Department of Labor recently issued updated model COBRA continuation coverage and Childrens’ Health Insurance Program (“CHIP”) notices. Plan administrators should begin using the new notices immediately. ...more

Proskauer - Employee Benefits & Executive...

New Guidance on COBRA and ACA Marketplace Coverage: The Gap in Coverage is (Not Quite) Filled

There has been much confusion and concern about the interplay between the COBRA continuation coverage rules and the new Health Insurance Marketplace established under the Affordable Care Act (the “Marketplace”). One important...more

Laner Muchin, Ltd.

Improve Compliance Of Retirement And Group Health Plans In 2014

Laner Muchin, Ltd. on

Retirement plan fiduciaries should consider the following best practices to improve their plan’s governance in 2014: (i) if fiduciary duties have been delegated, make certain that the delegations are in writing and are being...more

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