News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Premiums

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

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

Proskauer - Employee Benefits & Executive...

COBRA Election and Payment Periods: Does One Year of “Tolling” Really Mean One Year?

Remember the DOL/Treasury relief that tolled the COBRA election and payment deadlines for up to one year due to the COVID-19 pandemic (referred to below as “Tolling Relief”)? If you have been wondering whether, under that...more

Laner Muchin, Ltd.

New IRS Guidance Offers Employers Direction regarding COBRA Subsidy Obligations

Laner Muchin, Ltd. on

As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more

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

The New IRS COBRA Subsidy Guidance: Key Takeaways for Employers

The American Rescue Plan Act of 2021 (ARPA) implemented a 100 percent COBRA subsidy for certain qualified beneficiaries beginning on April 1, 2021, and ending September 30, 2021. On May 18, 2021, more than a month into the...more

Vinson & Elkins LLP

DOL Releases Temporary COBRA Subsidy Guidance For Employers

Vinson & Elkins LLP on

The Department of Labor (“DOL”) issued new guidance earlier this month on the temporary COBRA subsidies provided by the recently enacted American Rescue Plan Act (the “ARP”), which employers may find useful in administering...more

Smith Anderson

ARPA COBRA Subsidy's Impact on Employer Health Plans

Smith Anderson on

The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more

Parker Poe Adams & Bernstein LLP

U.S. Labor Department Answers Some - But Not All - Key Questions About New COBRA Subsidies

As previously reported in EmployNews, the American Rescue Plan Act provides “assistance eligible individuals” with the option to receive fully-subsidized COBRA coverage from April 1, 2021 through September 30, 2021....more

Fox Rothschild LLP

Department Of Labor Issues Guidance, Model Notices For COBRA Premium Subsidies Under The American Rescue Plan Act

Fox Rothschild LLP on

On April 7, 2021, the U.S. Department of Labor (DOL) issued much needed guidance to employers and their COBRA administrators on the “COBRA premium subsidy” provision of the American Rescue Plan Act (ARPA). This provision...more

Miles & Stockbridge P.C.

Part III: DOL Releases Model Notices for Mandatory COBRA Premium Subsidy

Under the American Rescue Plan Act of 2021 (ARPA), which was passed by Congress on March 11, 2021, the cost of health insurance coverage pursuant to the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) is...more

Holland & Knight LLP

DOL Releases Guidance and Model Notices for New COBRA Premium Subsidy

Holland & Knight LLP on

A COBRA subsidy program was enacted in March 2021 under the American Rescue Plan Act (ARPA). On April 7, 2021, the U.S. Department of Labor (DOL) released guidance and model notices on an information…...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

Sherman & Howard L.L.C.

Employee Benefit Plan Changes Under The American Rescue Plan Act

On March 11, 2021, President Biden signed the American Rescue Plan Act (ARPA). This Client Advisory focuses on the new mandatory and voluntary provisions for employee benefit plans and raises questions about the impact of the...more

Haynsworth Sinkler Boyd, P.A.

What’s Happening: FFCRA, PRO Act, COBRA Subsidies, Vaccinations And More!

The Biden Administration has directed a number of changes that impact employers under Administrative Agency action as well as the passage of the American Rescue Plan Act (ARPA). We are highlighting a few of those here to...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

BakerHostetler

Recently Issued Insurance Guidance Will Impact Ohio Employment-Based Health Plans

BakerHostetler on

In an effort to alleviate the COVID-19 public health threat, the Ohio Department of Insurance (ODI) issued bulletin 2020-03, titled “Health Insurance Coverage Flexibility for Ohio Employees” (the Bulletin), effective March 20...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 4 of 24): Highlights from the Draft 2015...

The IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C (“2015 Instructions”). These are the forms that employers with 50 or more full-time employees (including full-time equivalent employees) in the...more

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