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As 2021 winds down, retirement plan sponsors should confirm that their plan documents are amended by December 31, 2021, to comply with certain plan changes: • Hardship Distributions. 401(k) plans and 403(b) plans must be...more
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
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
Section 9501 of the American Rescue Plan Act of 2021 (“ARPA”) requires employers, multiemployer trustees and insurers (collectively, “plan administrators”) to provide a 100% subsidy for COBRA health care continuation coverage...more
On July 29, 2021, the Internal Revenue Service (IRS) updated the FAQs relating to paid sick and family leave tax credits under the American Rescue Plan Act of 2021 (ARPA). The update adds provisions that expand the...more
The American Rescue Plan Act of 2021 (ARPA) extends tax credits available to covered employers who provide qualified sick and family leave wages (within the meaning of ARPA) to their employees between April 1, 2021 through...more
On July 26, 2021, the IRS released Notice 2021-46 (the “Notice”), which provides new guidance on the 100% COBRA premium subsidies (the “Subsidies”) and the related tax credit under the American Rescue Plan Act of 2021 (March...more
The IRS just released some new supplemental guidance on the COBRA premium subsidy in the American Rescue Plan Act (“ARP”). IRS Notice 2021-46, released July 26, 2021 provides additional color on a handful of discrete subsidy...more
As we previously reported, the American Rescue Plan Act of 2021 (“ARPA”) created a special financial assistance program that is administered by the Pension Benefit Guaranty Corporation (“PBGC”) and intended to extend the...more
A case from the United States Court of Appeals for the Sixth Circuit highlights that, even in times of crisis like the COVID-19 pandemic, prioritizing federal grant money based on race and gender will likely violate the equal...more
One important question that arises when determining whether an individual is eligible for the COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”) is whether the employee has experienced an involuntary...more
COBRA notices and election forms are required to go out to assistance eligible individuals by May 31. Under the American Rescue Plan Act (“ARPA”), not only is COBRA subsidized for certain recipients but employers are also...more
The American Rescue Plan Act (ARPA) provides for 100% premium assistance to certain qualified beneficiaries for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) for periods of...more
The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it...more
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”). ARPA is the latest COVID-19-related stimulus legislation passed by Congress, but, unlike prior legislation, ARPA provides expansive...more
Due to tight timelines and an initial sprint to issue the special extended COBRA election period notices by the May 31st deadline, plan administrators may not have focused on the other COBRA-related notice requirements under...more
The American Rescue Plan (“ARP”) offers a special 60-day election period for certain individuals who previously declined or discontinued COBRA coverage (“Assistance Eligible Individuals” or “AEIs,” as defined in ARP). These...more
Employers should be busy preparing tailored COBRA continuation coverage notices for certain individuals, addressing complicated election and altered COBRA premium topics that took effect only in recent weeks. Below, we offer...more
This Holland & Knight alert is the first of several status updates on environmental justice (EJ) in the Biden Administration. It identifies early actions of the administration that are not only significant in their own right...more
On April 9, the U.S. Department of Labor (DOL) issued new guidance about the COBRA subsidy available under the American Rescue Plan Act (ARPA). Employers subject to COBRA must send out the updates notices as soon as possible...more
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
The American Rescue Plan Act (“ARPA”), signed into law on March 11, 2021, obligates employers to pay COBRA insurance premiums for individuals who suffer job loss. Under the plan, employers receive the subsidy, which they pass...more
While there may be light at the end of the tunnel, employers are facing lingering reminders of COVID-19 even as the pandemic subsides – including an increasing amount of litigation about how some have addressed virus-related...more
Please note: The below information may require updating, including additional clarification, as the COVID-19 pandemic continues to develop. As we have written about extensively, the Families First Coronavirus Response Act...more
The American Rescue Plan Act of 2021 (ARPA), signed into law on March 11, 2021, includes a whole host of requirements and provisions impacting private employers, their employees, and the benefit plans they offer....more