On Wednesday, the Internal Revenue Service (“IRS”) and Department of Treasury (“Treasury”) released guidance (Notice 2021-58) clarifying certain deadlines relating to COBRA continuation coverage in connection with the ongoing...more
The American Rescue Plan Act of 2021 (“ARPA”) includes a provision amending the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) to provide COBRA premium assistance to eligible individuals. The ARPA COBRA...more
In May 2020, the Department of Labor jointly with the Department of Treasury and the Internal Revenue Service (the “Agencies”) released guidance delaying and extending many common deadlines for employee benefit plans. In...more
The Department of Labor (“DOL”) posted new model notices on its website which employers may use to satisfy notice obligations under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), along with a short...more
As employers have noticed, there is a growing wave of COBRA notice class action lawsuits filed against large employers with at least six cases being filed in 2019 alone.
In each of the cases, the plaintiffs allege that the...more
Unlike the forms for the 2015 calendar year, the 2016 Forms 1095-C must be provided to employees by January 31 and must be submitted to the IRS electronically by March 31 (for those with under 250 forms submitting on paper,...more
If adopted, the changes would be effective for plan years beginning on or after January 1, 2019. The revisions affecting pension plans, and details regarding changes to Schedules H and I that affect funded plans (such as...more
Final rules have been issued regarding grandfathered plans, pre-existing conditions, rescissions, dollar limits, claims and appeals procedures, and patient protections. These rules, effective on the first day of the plan year...more