News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Employee Benefits Security Administration

Snell & Wilmer

2024 End-of-Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...more

Proskauer - Employee Benefits & Executive...

Benefit Plan Deadlines Extended for Individuals Affected by Recent Natural Disasters

Last week, the U.S. Departments of Labor and Treasury issued a Joint Notice requiring the extension of certain benefit plan deadlines for individuals affected by Hurricanes Helene and Milton and Tropical Storm Helene.[1] The...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Deadline Tolling

McDermott Will & Emery on

The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April...more

Patterson Belknap Webb & Tyler LLP

The End of the COVID-19 Emergency Declarations

Today marks the end of the COVID-19 public health emergency that first began on March 13, 2020. The end of the public health emergency has a wide range of implications for employer sponsored benefit plans. This alert...more

Snell & Wilmer

Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines

Snell & Wilmer on

The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985...more

Groom Law Group, Chartered

IRS Guidance Sheds Light on COBRA Premium Payment Deadlines in the Time of COVID-19

On October 6, 2021, the IRS released Notice 2021-58 (the “Notice”), which provides yet another round of guidance on the application of extended deadlines for COBRA elections and payments due to COVID-19. This guidance expands...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

Polsinelli

Department of Labor Provides Model Subsidized COBRA Notices and Additional Guidance

Polsinelli on

As described in our March 15, 2021 update, the American Rescue Plan Act of 2021 (the “Act”) created a temporary, 100% subsidy for assistance-eligible individuals’ premium payments for continuation health care coverage under...more

Faegre Drinker Biddle & Reath LLP

DOL Issues Model COBRA Subsidy Notices and Initial Guidance on COBRA Subsidy Relief under the American Rescue Plan Act of 2021

As discussed in our prior blog post, the American Rescue Plan Act of 2021 (ARP) requires employers that sponsor group health plans to provide a 100% COBRA subsidy for “Assistance Eligible Individuals” during the “Subsidy...more

Harris Beach Murtha PLLC

DOL Issues Model Notices, FAQs and Other Guidance About the ARP COBRA Premium Subsidy

On April 7, 2021, the U.S. Department of Labor (DOL) issued welcome guidance - including eagerly-anticipated model notices - to help employers and their COBRA administrators implement the temporary six-month (April 1 to...more

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

COBRA Subsidy: What We Know Now After Initial DOL Guidance

Less than a month after the American Rescue Plan Act of 2021 (ARPA) was signed into law, new U.S. Department of Labor (DOL) guidance and model forms are clearing up a number of employer concerns about the 100 percent COBRA...more

Perkins Coie

EBSA Guidance on COBRA Subsidy in the American Rescue Plan Act

Perkins Coie on

The American Rescue Plan Act of 2021 (ARPA) provides a 100% federal subsidy of COBRA premiums from April 1, 2021, through September 30, 2021, for certain COBRA participants known as Assistance Eligible Individuals (AEIs). Our...more

Ruder Ware

Department of Labor Posts ARPA COBRA Subsidy Notices; Dedicated Web Page

Ruder Ware on

Today the Employee Benefits Security Administration (EBSA), the section of the Department of Labor that handles all things employee benefit plans, posted a dedicated webpage with much anticipated (and much needed) employer...more

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

DOL Guidance Clarifies Expiration of COVID-19 Deadline Extension for Employee Benefit Plans

The U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published EBSA Disaster Relief Notice 2021-01 in the nick of time on February 26, 2021. EBSA Disaster Relief Notice 2021-01 was released...more

Bradley Arant Boult Cummings LLP

DOL Guidance on Applying One-Year Limit to COVID-19 Outbreak Period Extensions

In EBSA Disaster Relief Notice 2021-01, the Department of Labor (DOL) has issued a critical interpretation of prior guidance that extended certain deadlines for employee benefit plans, participants, and beneficiaries due to...more

Husch Blackwell LLP

New Developments: Clarification On Extensions Of Benefit Deadlines

Husch Blackwell LLP on

On February 26, 2021, the Department of Labor, the Treasury Department and Internal Revenue Service issued clarifying guidance regarding COVID-19-related deadline extensions under the Internal Revenue Code, ERISA, COBRA and...more

Mintz - Employment Viewpoints

Agencies Issue Needed Guidance on COBRA Elections During the COVID-19 “Outbreak Period”

On February 26, 2021, the Department of Labor’s Employee Benefits Security Administration (EBSA) issued Notice 2021-01 (the “Notice”). The Notice was issued jointly with the Department of the Treasury, the Internal Revenue...more

Stoel Rives LLP

Outbreak Period to Be Applied on a One-Year Rolling Basis

Stoel Rives LLP on

In this legal update, our employee benefits attorneys cover three recent health and welfare plan developments....more

Foley & Lardner LLP

IRS and DOL Clarify Extended Deadlines for Benefit Plans and Encourage Employer Notices

Foley & Lardner LLP on

Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) issued two notices that extended certain benefit plan deadlines for both employees/plan participants and for plan administrators as a result of...more

Tarter Krinsky & Drogin LLP

Update: Employee Benefit Plan Notice Requirements

DOL Issues Guidance on Continuing COVID-19 Relief for Employee Benefit Plans, Plan Participants, and Beneficiaries Recognizing that many employee benefit plan participants and beneficiaries continue to struggle with ongoing...more

Williams Mullen

Department of Labor Issues Guidance on Continued COVID-19 Timeframe Relief

Williams Mullen on

Last year, the Internal Revenue Service (IRS) and the Department of Labor (DOL) jointly offered extensions and other relief to employee benefit plan administrators who might be struggling to meet various filing, notice,...more

Robinson & Cole LLP

EBSA Notice and COBRA Extension Expiration

Robinson & Cole LLP on

Early Friday, the Employee Benefits Security Administration (EBSA) released Notice 2021-01 (the Notice) providing guidance to employers and COBRA administrators on the duration of the previously-issued COVID-19-related relief...more

Morgan Lewis - ML Benefits

Suspended Deadlines Under ERISA, Part Two: Sound the Alarm!

At the 11th hour, the US Department of Labor’s Employee Benefits Security Administration (EBSA), with coordination and review by the Internal Revenue Service and the Department of Health and Human Services (collectively, the...more

Proskauer - Employee Benefits & Executive...

We Now Know For Whom the Statute Tolls

In our February 12th blog post, we raised the question of how to interpret the duration of the DOL/Treasury relief tolling certain benefit plan deadlines due to the COVID-19 pandemic. Without guidance from the agencies, it...more

Bradley Arant Boult Cummings LLP

DOL Clarifies One-Year Limitation on COVID-19 Deadline Extensions — New Notices May Be Required

In EBSA Disaster Relief Notice 2021-01, the Department of Labor (DOL) has issued a critical interpretation of prior guidance that extended certain deadlines for employee benefit plans, participants, and beneficiaries due to...more

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