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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

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

ARPA COBRA Subsidy Model Notices and Guidance Released Today Requires Immediate Action

Ahead of its April 11, 2021 deadline, the U.S. Department of Labor (“DOL”) has issued some guidance and model notices related to the temporary 100% subsidy for COBRA health care continuation coverage (including under state...more

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

PBGC Q&As: Impact of COVID-19 and CARES Act on Single-Employer Pension Plans

The Pension Benefit Guaranty Corporation (“PBGC”) has posted questions and answers (“Q&As”) related to the impact that COVID-19 and the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136 (March 27, 2020) (the...more

IRS Guidance on 2020 RMD Waivers Includes Rapidly Approaching Rollover Deadline

Two significant changes affecting required minimum distributions under Section 401(a)(9) of the Internal Revenue Code have been made in the most recent two years...more

FAQs Part 43: Guidance on Health Coverage Issues Related to COVID-19

The HHS, DOL and IRS have released additional guidance in the form of frequently asked questions (FAQs) regarding health coverage issues related to the 2019 novel coronavirus (“COVID-19”),1 including under the Families First...more

IRS Notice 2020-50: Guidance on Coronavirus Related Distributions and Loans

The Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136 (the “CARES Act”) became law on March 27, 2020. For information about the CARES Act, please see our summary. Among other things, Section 2202 of the...more

Now on the COVID-19 Menu: Temporary Flexibility for Cafeteria Plans

With the 2019 novel coronavirus (“COVID-19”) national health emergency continuing, employers are continuing to try to find ways to help their employees. In response to requests from employers, the Internal Revenue Service...more

For Whom the Timing Tolls: The COVID-19 Outbreak Period Interrupts Benefit Plan Deadlines

New employee benefits guidance temporarily extends certain time frames and deadlines for participant actions and relieves some plan administration compliance obligations during the COVID-19 National Emergency (the “COVID-19...more

How Employers Can Assist Employees (Current and Former) Right Now

Countless employers have been forced to reduce employees’ hours or terminate employees due to the 2019 novel coronavirus (“COVID-19”). Federal and state governments are working to pass stimulus legislation to assist the...more

Health Plan Coverage of Coronavirus Testing and Treatment

With the news about the spread of the 2019 novel coronavirus (“COVID-19”) in the U.S. and the world rapidly evolving, group health plan sponsors need to address how the plan will provide virus-related benefits. ...more

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