News & Analysis as of

American Rescue Plan Act of 2021 Department of Labor (DOL)

Snell & Wilmer

2022 End of Year Plan Sponsor “To Do” List (Part 3) Qualified Retirement Plans

Snell & Wilmer on

As 2022 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. Part 1 covered health and welfare plan...more

Foley & Lardner LLP

Health Providers Must Avoid COVID Reimbursement Missteps

Foley & Lardner LLP on

One Health Resources and Services Administration program, “COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured,” has been a huge source of...more

Jackson Lewis P.C.

A Brief Status Report On COBRA

Jackson Lewis P.C. on

The normal difficulties that employers have adhering to the technical requirements of COBRA have been exacerbated during the past two years as COBRA rules were changed to recognize the complications accompanying the COVID-19...more

Morgan Lewis - ML Benefits

DOL Updates Form 5500 for PEPs and MEPs; No Decision Yet on Group of Plan Issues

The US Department of Labor (DOL) issued a final regulation (Final Rule) on December 29, 2021, updating the 2021 Form 5500 to reflect certain statutory changes included in the Setting Every Community Up for Retirement...more

Seyfarth Shaw LLP

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

Seyfarth Shaw LLP on

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

Verrill

IRS Issues Guidance Clarifying the Application of COVID-19 Outbreak Period Extensions for Electing COBRA Continuation Coverage and...

Verrill on

On October 6, 2021, the IRS issued Notice 2021-58, providing helpful guidance on COBRA continuation coverage in two key areas: (1) the application of the extended timeframes for electing COBRA continuation coverage and paying...more

Laner Muchin, Ltd.

Reminder: Employers Have Until September 15 to Issue COBRA Subsidy Termination Notices

Laner Muchin, Ltd. on

As previously reported, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA payments for a COBRA qualified beneficiary who becomes eligible for COBRA due to a reduction in hours or involuntary...more

Sheppard Mullin Richter & Hampton LLP

ARPA COBRA Subsidy Expiration Notice Due by September 15

The American Rescue Plan Act (“ARPA”) requires the full cost of COBRA premiums to be subsidized for COBRA continuation coverage during the period from April 1, 2021 through September 30, 2021 (“Subsidy Period”) of certain...more

Williams Mullen

COBRA Subsidy Expiration Notice is Due September 15

Williams Mullen on

The American Rescue Plan Act of 2021 (the ARPA), signed into law this spring, included premium relief to certain COBRA-qualified beneficiaries that is set to expire September 30, 2021. ...more

Morgan Lewis - ML Benefits

American Rescue Plan Act of 2021 COBRA Subsidy Expiration Notice Is Due

The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy for up to six months, from April 1, 2021 through September 30, 2021, for Assistance Eligible Individuals (AEIs) as defined under the...more

Bond Schoeneck & King PLLC

Advance Notice Required Before COBRA Subsidy Ends

Group health plan sponsors that are providing the temporary COBRA premium subsidy required by the American Rescue Plan Act (ARPA) must provide advance notice to certain recipients that the COBRA subsidy will end. The notice...more

Snell & Wilmer

Better Late Than Never: IRS Issues Guidance Clarifying COBRA Premium Subsidy Rules

Snell & Wilmer on

S&W Insight: The IRS clarified several trailing issues with respect to COBRA premium subsidies under the American Rescue Plan Act, including extended election periods, eligibility for other coverage, and rules about...more

Verrill

Employee Benefits & Executive Compensation 2021 Summer Client Advisory

Verrill on

This Client Advisory summarizes developments in the law governing employee benefit plans prompted by the COVID-19 pandemic. We explain what these developments mean for plan sponsors and highlight the need to adopt plan...more

Jackson Lewis P.C.

The End Of A (Short) Era: ARPA COBRA Subsidies And The Remaining Action Item For Plan Sponsors

Jackson Lewis P.C. on

The American Rescue Plan Act of 2021 (“ARPA”) kept many practitioners busy this spring/summer. Under one of ARPA’s most impactful provisions, employees who were involuntarily terminated or had their hours reduced (and...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Beltway Buzz - August 2021

RIP, Richard Trumka. AFL-CIO President Richard Trumka died unexpectedly this week at the age of 72. A former coal miner, Trumka became president of the United Mine Workers of America in 1982....more

McDermott Will & Emery

Weekly IRS Roundup July 5 – July 9, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 5, 2021 – July 9, 2021... July 6, 2021: The IRS—in conjunction with the US Department of...more

BCLP

Are Your COBRA Notices Sufficient to Avert a Costly Challenge?

BCLP on

While the Consolidated Omnibus Budget Reconciliation Act (“COBRA”) continuation coverage subsidy requirements imposed by the American Rescue Plan Act of 2021 are at the forefront of employers’ minds, recent litigation trends...more

Holland & Knight LLP

Biden Administration Report Outlines Strategy to Invigorate Domestic Supply Chains

Holland & Knight LLP on

The Biden Administration on June 8, 20201, released findings from a 100-day interagency domestic supply chain assessment of critical products and outlined a series of steps it will take in order to strengthen U.S. critical...more

Proskauer - Employee Benefits & Executive...

Calculating the ARP COBRA Premium Subsidy Tax Credit

On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice...more

Snell & Wilmer

Subsidized COBRA Elections under ARPA Override COBRA Election Deadline Extensions

Snell & Wilmer on

As detailed in our SW Benefits Update, “Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act,” the IRS recently released Notice 2021-31 (the “Notice”), providing welcome...more

Proskauer - Employee Benefits & Executive...

All Good Subsidies Must Come to an End, Part II: The IRS Adds Some Nuances

In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice.  This post revisits the topic in light of...more

Snell & Wilmer

Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act

Snell & Wilmer on

The American Rescue Plan Act (“ARPA”) has been the law of the land since March 11, 2021. Even so, many questions remained unanswered with respect to ARPA’s impact on group health plans. To resolve some of the lingering...more

McDermott Will & Emery

How to Apply the IRS’s COBRA Premium Subsidy Guidance

On May 18, 2021, the Internal Revenue Service (IRS) issued much-anticipated Notice 2021-31 (the Notice) regarding the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy provisions of the American Rescue...more

Troutman Pepper

IRS Issues Guidance on Federally Funded COBRA Premium Subsidy: FAQs and What You Need to Know

Troutman Pepper on

On March 25 and April 15, Troutman Pepper reported on the 100% federally funded COBRA premium subsidy included in the American Rescue Plan Act (ARPA), noting the need for additional guidance on a number of issues. On May 18,...more

Lowenstein Sandler LLP

IRS Issues COBRA Subsidy Guidance

Lowenstein Sandler LLP on

On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA), which provides temporary premium assistance for health, dental, and vision coverage under the Consolidated Omnibus Budget...more

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