News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Premium Subsidies

Woods Rogers

Does the Fun Ever Stop? COVID-19 Tolling Ends for COBRA Deadlines

Woods Rogers on

On April 10, 2023, President Biden signed legislation to end the COVID-19 national emergency effective immediately, including ending the requirement to extend COBRA deadlines due to the COVID-19 pandemic. Plan administrators...more

McDermott Will & Emery

IRS Provides New Guidance on COBRA Election and Payment Deadlines

McDermott Will & Emery on

In Notice 2021-58 (the Notice), the Internal Revenue Service (IRS) clarified that the one-year tolling relief periods for Consolidated Omnibus Budget Reconciliation Act (COBRA) elections and initial premium payments run...more

Ballard Spahr LLP

IRS Issues New Guidance on COBRA Deadline Extensions

Ballard Spahr LLP on

The IRS (with the concurrence of the DOL and HHS) has issued new guidance explaining how the extension of the deadline for paying COBRA premiums will be applied. ...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

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

Lowenstein Sandler LLP

Navigating the Nuances of the COBRA Subsidy Under the American Rescue Plan Act

Lowenstein Sandler LLP on

Hosts Andrew Graw and Megan Monson discuss the American Rescue Plan Act of 2021 (ARPA) as part of the new (third) COVID-19 stimulus relief bill. The ARPA assists qualifying individuals who lose coverage under an employer’s...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

Epstein Becker & Green

COBRA Premium Assistance Period Ends September 30, 2021

Epstein Becker & Green on

On September 30, 2021, the COBRA premium assistance period established by the American Rescue Plan Act (“ARPA”) will come to an end. ARPA requires, among other things, that employers provide 100 percent COBRA premium...more

Ballard Spahr LLP

Reminder: COBRA Subsidy to End, Notice of Termination Required

Ballard Spahr LLP on

The subsidy for COBRA coverage under the American Rescue Plan Act comes to an end on September 30, 2021. There is no indication at this time that the subsidy will be extended....more

Troutman Pepper

ARPA COBRA Premium Assistance Expiration: A Friendly Reminder for Employers

Troutman Pepper on

Who Needs to Know - Employers. Why It Matters - A COBRA subsidy has been offered through September 30. Employers must provide notice to participants that the subsidy is ending no later than September 15, 2021....more

Pullman & Comley - Labor, Employment and...

COBRA Update: Final COBRA Subsidy Termination Notices Now Due

As mentioned in our prior COBRA update, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA premium payments. The subsidy is available to COBRA qualified beneficiaries who become eligible for COBRA...more

Akerman LLP - HR Defense

Deadline Triggered as COBRA Premium Subsidy Ends

Employers and plans are reminded that they must provide a COBRA subsidy expiration notice no later than September 15, 2021, pursuant to the American Rescue Plan Act of 2021 (ARPA). ARPA had included some new COBRA obligations...more

McNees Wallace & Nurick LLC

DON’T FORGET – The COBRA Premium Subsidy Expiration Notice Deadline is September 15th

The 100-percent premium subsidy for eligible COBRA health care enrollees, enacted earlier this year as part of the American Rescue Plan Act (ARPA), period is ending September 30, 2021....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

Locke Lord LLP

September 30, 2021 Marks the End of the COBRA Premium Subsidy ‎–‎ Don’t Overlook the Expiration Notice

Locke Lord LLP on

The American Rescue Plan Act of 2021 provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible individuals (AEIs). With the COBRA subsidy period...more

Stinson LLP

COBRA Premium Assistance Expiration Notice Deadline Approaching

Stinson LLP on

The COBRA premium assistance period, as part of the American Rescue Plan Act, will expire on September 30, 2021. Plans are required to send notices to assistance eligible individuals (AEIs) to inform them about the subsidy's...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

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

It’s Not Over ‘Til It’s Over: The COBRA Premium Subsidy is Ending

As we mentioned in our May 23, 2021, article, the American Rescue Plan Act of 2021 (ARPA) provides a 100 percent premium subsidy for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA)...more

Blank Rome LLP

As If Employers Didn’t Have Enough to Worry About, Don’t Skip the ARPA Cobra Subsidy Expiration Notice

Blank Rome LLP on

As we explained in our April 16, 2021, post, the American Rescue Plan Act of 2021 (“ARPA”) requires employers to subsidize the cost of Consolidated Omnibus Budget Reconciliation Act (“COBRA”) continuation coverage and state...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

Seyfarth Shaw LLP

Never Fear: More COBRA Subsidy Guidance Is Here

Seyfarth Shaw LLP on

On July 26, 2021, the U.S. Internal Revenue Service (“IRS”) issued Notice 2021-46, providing additional guidance on the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) and premium assistance and tax credit...more

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

IRS Issues Additional Guidance on the COBRA Subsidy

On July 26, 2021, the Internal Revenue Service (IRS) released Notice 2021-46 to provide additional guidance on the Consolidated Omnibus Budget Reconciliation Act (COBRA) subsidy under the American Rescue Plan Act of 2021...more

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