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Whiplash: The Orderly and Disorderly End to the COVID-19 Declarations

Summary - Sponsors of employee benefit plans face heightened plan design and administrative challenges in the wake of President Biden’s surprise termination of the COVID-19 national emergency. This unexpected development,...more

Impact of May 11, 2023 End of COVID-19 Emergency Declarations

On January 30, 2023, the Biden Administration said that it will end COVID-19 emergency declarations on May 11, 2023. The federal government has been paying for COVID-19 vaccines, some tests, and certain treatments under the...more

IRS Issues New Guidance on COBRA Deadline Extensions

The IRS (with the concurrence of the DOL and HHS) has issued new guidance explaining how the extension of the deadline for paying COBRA premiums will be applied. ...more

Reminder: COBRA Subsidy to End, Notice of Termination Required

The subsidy for COBRA coverage under the American Rescue Plan Act comes to an end on September 30, 2021. There is no indication at this time that the subsidy will be extended....more

COBRA Premium Subsidies - A Little More Guidance (and a Reminder)

The IRS issued a new notice that provides guidance on a few issues that were not fully addressed in its earlier notice on the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy requirements set forth in...more

Reminder: COBRA Notice Deadline is May 31

This is a reminder that a COBRA notice deadline is approaching. It applies to employers that are subject to the federal COBRA rules....more

IRS Weighs in on ARPA COBRA Subsidy

Summary - The IRS issued guidance on a wide range of questions pertaining to the subsidies that employers are required to offer to COBRA qualified beneficiaries under the American Rescue Plan Act....more

Q&A: COBRA Subsidies Under the American Rescue Plan

The U.S. Department of Labor issued guidance on April 7 about the new COBRA subsidy rules under the American Rescue Plan (ARP). However, the DOL left some significant questions unanswered....more

ARP: COBRA Premium Assistance

The United States Department of Labor has issued much anticipated guidance and model forms under the COBRA subsidy rules introduced by the American Rescue Plan (ARP). The FAQ guidance and forms clarify some issues that...more

ARP: Employee Benefits and Executive Compensation

The American Rescue Plan (ARP) will have significant and immediate impacts on employee benefit plans, employers, and other plan sponsors and plan administrators. ...more

A Rolling Extension: New Guidance on Employee Benefit Deadlines

The U.S. Department of Labor issued a notice that addresses how the extension announced last year for certain employee benefit deadlines will apply now that the commencement date for the extension has passed its one-year...more

IRS Issues New Flexible Spending Account Rules

The IRS issued a notice that addresses many of the questions employers have raised about flexible spending accounts (FSAs) in view of the new rules set forth in the Consolidated Appropriations Act (CAA)....more

COBRA Subsidies Included in Latest Stimulus Proposal

Group health plan sponsors and administrators may soon need to introduce changes to their offer of continued coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). The House Education and Labor...more

Year-End COVID-19 Considerations for Health and Welfare Plans

Summary - COVID-19 has dominated the agenda for health and welfare benefits in 2020. From suspended deadlines to mid-year election changes to enhanced cost-free coverage, the pandemic has resulted in significant changes to...more

CMS Addresses Extended Deadlines for Benefit Plans

The Department of Health and Human Services Centers for Medicare & Medicaid Services (CMS) has followed the guidance, jointly issued by the U.S. Departments of Labor and the Treasury, that extends benefits-related deadlines...more

DOL and Treasury Extend Benefits-Related Deadlines

To reduce the risk that participants will lose benefits during the COVID-19 outbreak because they fail to meet certain procedural requirements, the U.S. Departments of Labor and the Treasury announced the extension of a...more

Employee Benefits and Furloughs in the Era of COVID-19

Across the United States, employers are carefully considering how the COVID-19 pandemic is affecting their business. As we await further guidance and pronouncements from federal, state, and local officials, some employers are...more

Reporting for ACA Mandates: Final Forms and Additional Guidance

The IRS has finalized the 2015 forms and instructions for reporting under the individual and employer mandates and issued additional guidance on these new reporting requirements. The following forms are now available...more

New FAQs Address Effect of Affordable Care Act on COBRA and Other Matters

In a wide-ranging set of frequently asked questions (FAQs) and other guidance, the U.S. Departments of Labor, Treasury, and Health and Human Services have addressed a number of issues pertaining to the Affordable Care Act...more

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