News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act U.S. Treasury

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

Husch Blackwell LLP

The End of the COVID Emergency and Its Impact on Group Health Plan Coverage Requirements

Husch Blackwell LLP on

After nearly three years of emergency measures related to COVID-19, the U.S. government acted this spring to officially end the COVID-19 Public Health Emergency and the National Emergency. Accordingly, the Departments of...more

King & Spalding

President Biden Signs Bill Ending COVID-19 National Emergency

King & Spalding on

Last week, President Biden signed legislation formally ending the COVID-19 national emergency that was originally declared under the Trump administration in March 2020. The bill to end the national emergency, H. J. Res. 7,...more

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

No Change in DOL/Treasury Guidance for Employer Health Plans Issued Before Declared End of COVID-19 National Emergency

What does the April 10, 2023, early end of the COVID-19 National Emergency declaration mean for employer health plans? Well, nothing, actually....more

Bradley Arant Boult Cummings LLP

The End of the COVID-19 Public Health Emergency: Federal Agencies Clarify Coverage Implications for Group Health Plans

With the COVID-19 Public Health Emergency (PHE) set to end on May 11, 2023, the Department of Labor, Department of the Treasury, and Department of Health and Human Services (the “departments”) have published FAQs explaining...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers

The Biden administration has announced its intention 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)....more

Proskauer - Employee Benefits & Executive...

It’s Over: DOL, Treasury, and HHS Confirm End of (Most) COVID-19 Rules for Health Plans

Earlier this week, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) jointly issued guidance confirming that most COVID-19-related benefit coverage mandates, as well as the special tolling...more

Sherman & Howard L.L.C.

The End of the Line Draws Near for COVID-19 Plan Deadline Extensions

On January 30, 2023, the Biden Administration released a Statement of Administration Policy providing that the Administration intends to end the COVID-19 National Emergency declared in 2020 (the “National Emergency”) on May...more

Proskauer - Employee Benefits & Executive...

The Long-Awaited End of the Tolling of Plan Deadlines due to COVID-19

The Biden Administration recently announced that the COVID-19 National Emergency will end on May 11, 2023. This means that the requirement to extend various benefit plan deadlines due to the COVID-19 pandemic will end as...more

Faegre Drinker Biddle & Reath LLP

COVID-19 National Emergency Plan Deadline Extensions Set to End This Summer

On January 30, 2023, President Biden announced the Administration’s plan to extend the current declarations of the COVID-19 national emergency and public health emergency (PHE) through May 11, 2023, and end both emergencies...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

Proskauer - Employee Benefits & Executive...

The Wait is Over: Treasury and IRS Release COBRA Premium Subsidy Guidance

Today, the Treasury Department and the IRS released detailed questions and answers providing guidance on various implementation issues related to the COBRA premium subsidy under the American Rescue Plan Act of 2021 (ARP)....more

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

Beltway Buzz - April 2021 #2

Infrastructure Plan Scuttlebutt. With Congress not returning to Washington, D.C., until next week, the White House’s American Jobs Plan proposal is still driving much of the political discussion in town this week. Of course,...more

Mitchell, Williams, Selig, Gates & Woodyard,...

DOL Publishes Model COBRA Notices and Premium Assistance Guidance

On April 7, 2021, the U.S. Department of Labor (DOL) posted model COBRA notices and issued FAQ guidance addressing the recently-enacted COBRA coverage subsidy. The FAQ guidance specifies that individuals may be eligible...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

Dentons

COBRA Premium Subsidies Under the American Rescue Plan Act

Dentons on

The American Rescue Plan Act requires employers to subsidize 100% of the cost of COBRA and comparable state continuation coverage for “assistance eligible individuals” from April 1, 2021, through September 30, 2021. 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

Proskauer - Employee Benefits & Executive...

For Whom the Statute Tolls

As discussed in an earlier blog post on the DOL/Treasury relief extending benefit plan deadlines due to the pandemic, plans have to disregard an “outbreak period” when determining deadlines for COBRA elections and premiums...more

Troutman Pepper

D.C. Circuit Upholds Short Term Plans as Alternative to ACA Plans

Troutman Pepper on

On July 17, 2020, a panel majority of the D.C. Circuit Court of Appeals upheld a rule issued by the Department of Treasury, the Department of Labor, and the Department of Health and Human Services (collectively, the...more

Fisher Phillips

New Benefit Plan Deadline Extensions Provide Opportunities For Participants – And Burdens For Plan Sponsors

Fisher Phillips on

The Department of Labor (DOL), in coordination with the IRS and the Treasury Department, recently issued new rules extending key deadlines for health, retirement, and welfare plans subject to ERISA and the Internal Revenue...more

Snell & Wilmer

Help for Employees Can Equal Headaches for Employers: Agencies Issue More Health and Welfare Relief for COVID-19

Snell & Wilmer on

With the COVID-19 pandemic putting pressure on employers and employees alike, the Department of Labor (“DOL”), Treasury (“Treasury”), and Health and Human Services (“HHS”) (collectively, the “Departments”) continue to issue...more

Epstein Becker & Green

DOL Gives Extra Time to Plan Participants and Beneficiaries: Benefits Guidance in the Time of COVID-19

Epstein Becker & Green on

Plan participants and their beneficiaries may now have extra time to exercise some of their rights under the employee benefit plans in which they participate. ...more

Dechert LLP

DOL and Treasury Defang COBRA’s Deadlines in a Time of National Emergency

Dechert LLP on

A national emergency was declared on March 13, 2020, as the result of the COVID-19 pandemic. As a result of that declaration, the Federal Emergency Management Agency (FEMA) issued emergency declarations for every state,...more

Benesch

DOL and Treasury Provide Relief from Certain ERISA Deadlines for Benefit Plans and Participants

Benesch on

On April 29, 2020, the Department of Labor and the Department of the Treasury (“Treasury”) issued guidance providing relief for employee benefit plans in the context of the COVID-19 pandemic. The guidance includes the...more

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