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We Have No Idea When The Outbreak Period Will End, But We Have a Better Idea When COBRA Payments are Due

Seyfarth Synopsis: The IRS has attempted to provide clarity (following the DOL’s earlier attempt) on how the coronavirus Outbreak Period will work and how it applies  to COBRA election and premium payment deadlines, in Notice...more

IRS Releases Extensive Guidance on ARPA COBRA Subsidy

Seyfarth Synopsis: On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”), which requires plan sponsors to provide free COBRA coverage from April 1, 2021 through September 30, 2021, to...more

Freedom Ain’t Free. COBRA, On the Other Hand…

Seyfarth Synopsis: The latest COVID relief bill, the American Rescue Plan Act (ARPA), provides for a 100% COBRA premium subsidy from April 1, 2021 through September 30, 2021. ARPA, which was signed into law by President...more

DOL Issues Clarification of Outbreak Period - Sort of

At the 11th hour, on February 26, 2021, the Department of Labor (DOL) issued EBSA Disaster Relief Notice 2021-01 (the “Notice”) to provide guidance on the duration of the COVID-related relief previously provided by the DOL in...more

Oh What a Relief It Is - For Health Plan Participants

Seyfarth Synopsis: On Tuesday, shortly after the IRS extended deadline relief to employee benefit plans, the U.S. Department of Labor granted its own relief for a number of deadlines related to the administration of employee...more

Issue 92: IRS Releases Final Employer Reporting Forms and Instructions

As we previously reported in Issue 80, the Affordable Care Act (ACA) requires providers of minimum essential health coverage and applicable large employers to file annual reports with the IRS to report the coverage provided...more

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