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Health and Welfare Plan Year-End Reminders

Permissible Flexibility under Code Section 125 Pursuant to IRS Notice 2021-15 Notice 2021-15 offered plan sponsors the flexibility to adopt any of the following options despite the longstanding rules under Section 125 of the...more

IRS Provides Second Round of FAQs on COBRA Subsidies

As we get closer to the September 30 expiration date of the COBRA premium subsidy provided under the American Rescue Plan Act (ARPA), the IRS has issued a second set of FAQs in Notice 2021-46 (Notice) to supplement its prior...more

IRS Issues Guidance Regarding American Rescue Plan Act COBRA Subsidy

The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more

Biden-Harris Administration’s First 100 Days Expose Priorities, Lay Groundwork for New Policies

US President Joseph Biden and Vice President Kamala Harris have consistently framed their policies with what they call the four major “crises” facing the nation: COVID-19, the economy, climate, and inequity. ...more

DOL Issues ARPA COBRA Subsidy Model Notices and FAQs

As we described in our March 15, 2021 LawFlash, the American Rescue Plan Act of 2021 (ARPA) includes a 100% COBRA premium subsidy for any employee or dependent who is a COBRA qualified beneficiary ...more

American Rescue Plan’s Health and Welfare Benefit Provisions: COBRA and DCFSA Action Items

The American Rescue Plan Act of 2021 includes a COBRA premium subsidy and increases the dependent care flexible spending account (DCFSA) limits. While the availability of the COBRA premium subsidy is a requirement, the...more

Initial Key Takeaways from the American Rescue Plan Act of 2021

President Joseph R. Biden signed the American Rescue Plan Act of 2021 on March 11, which provides $1.9 trillion in relief funds across a broad spectrum of categories, including additional support for vaccine distribution,...more

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