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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

COBRA-Related Litigation Trend: Advanced Preparation Is the Anti-Venom

Over the past two years, there has been a steady uptick of class action litigation alledging deficiencies in the notices that employers are required to provide under the Consolidated Omnibus Budget Reconciliation Act of 1985,...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

U.S. Supreme Court Decisions on Same-Sex Marriages Impact Employee Benefits

On June 26, 2013, the U.S. Supreme Court (the “Court”) issued two decisions, finding that federal and California laws on same-sex marriages are unconstitutional. These decisions will have far-reaching and wide-ranging...more

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