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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

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

Have You Thought About ... What the Limited Extension to the FFCRA Means to Employers?

The Families First Coronavirus Response Act (“FFRCA”) ended by its terms on Dec. 31, 2020. Although many expected the FFCRA protections to be extended due to the continuing pandemic, only a portion of the FFCRA was extended...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

Analysis of Economic Provisions in HEROES Act

On May 12, House Democrats unveiled the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES) Act. Democratic leadership intends to bring the legislation to the floor for a vote on Friday. The bill is the...more

IRS FAQs Allow Taxes Withheld from Employees’ Wages to Fund Leave and Wage Payments

The Internal Revenue Service (IRS) recently provided guidance, in the form of frequently asked questions (FAQs) related to the refundable payroll tax credits for the paid family and sick leave required to be provided by...more

Analysis of Senate-Passed CARES Act

On March 25, the Senate approved a $2 trillion stimulus package, the Coronavirus Aid, Relief, and Economic Security Act, to address the economic and health impacts of the COVID-19 pandemic. The bill now moves to the House for...more

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