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Navigating the Nuances of the COBRA Subsidy Under the American Rescue Plan Act
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The Consolidated Appropriations Act of 2021 generally requires group health plans and health insurance issuers to submit a Gag Clause Prohibition Compliance Attestation (Attestation) each year to demonstrate compliance with...more
Does your company's health plan provide prescription drug coverage? If so, you have until October 15, 2023 to send a notice to individuals who are enrolled in Medicare Part A or Part B and are eligible for the company's...more
Employers, this is your annual reminder that the Centers for Medicare & Medicaid Services (CMS) requires sponsors of group health plans to notify eligible individuals whether the employer’s prescription drug coverage is...more
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
President Biden recently announced his intention to end the COVID-19 National Emergency and Public Health Emergency effective May 11, 2023. As we previously discussed here, those emergency declarations had significant impacts...more
Air ambulance services often result in large, unanticipated medical bills for patients. A study by the Government Accountability Office found that in 2017, 69% of air ambulance transports provided to individuals covered by...more
Applicable large employers must adhere to many Affordable Care Act (ACA) rules to remain compliant regarding group health plan offerings. We offer the following checklist of the five most helpful reminders you should take...more
The July 1st deadline is quickly approaching for non-grandfathered group health plans and issuers to publicly disclose, in accordance with the Transparency in Coverage Final Rules, price information in machine-readable files...more
On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt is joined by his colleague, Allison Carlon, who helps us better understand what employers need to know about the Consolidations Appropriations Act...more
The January 1, 2022, deadline is approaching for plan sponsors to post the required notice informing participants of certain changes affecting how medical benefits may be billed under their health plan. This notice is...more
The Internal Revenue Service (IRS) has published proposed regulations that, if finalized, will ease some of the requirements imposed on employers reporting offers of minimum essential health coverage, including a permanent...more
Group health plan sponsors are required to send annual notices (as well as at other particular times) to individuals who are eligible for Medicare Part D that explain whether the health plan’s prescription drug coverage is...more
Group health plan sponsors soon will face daunting new disclosure and transparency requirements under multiple laws including the Affordable Care Act (ACA), the No Surprises Act (the Act) and the Consolidated Appropriations...more
The American Rescue Plan Act of 2021 (ARPA) mandates that group health plans that are subject to COBRA must provide coverage to certain assistance eligible individuals (AEI) at no cost for periods of coverage between April 1,...more
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
Carlton Fields tax attorney Lowell Walters explains what we can learn about a recent case in which a former employee claimed to be owed benefits, and provides suggestions on how companies can protect themselves. The video...more
At the last minute, certain suspended COBRA, HIPAA and claims procedure deadlines that were set to expire on February 28, 2021 have been further extended. As we discussed last year the Department of Labor (DOL) and Internal...more
The Department of Labor (DOL) recently issued EBSA Disaster Relief Notice 2021-01 (the “Notice”), which provides guidance on expiration of the COVID-19 extended participant deadlines. The COVID-19 extended participant...more
As we described in our LawFlash from last spring, the US Department of Labor’s Employee Benefits Security Administration (EBSA) and the Internal Revenue Service (IRS) (collectively, the Agencies) issued EBSA Notice 2020-01...more
There has been a recent flurry of regulatory guidance issued affecting employee benefit plans. Most of the guidance addresses challenges specifically created by the COVID-19 pandemic, while other guidance is applicable...more
Troutman Sanders and Pepper Hamilton are producing a series of podcasts to discuss employee benefits, executive compensation, and labor and employment issues that employers are confronting in light of the COVID-19 pandemic,...more
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
This post summarizes the health and welfare benefit plan-related deadline extensions described in IRS Notice 2020-23 issued April 9, 2020 and the DOL and Treasury Joint Notice issued April 28, 2020 (the “Joint Notice”). IRS...more
The US Department of Labor, in conjunction with the Internal Revenue Service and US Department of the Treasury, issued guidance and deadline extensions applicable to ERISA-governed group health and welfare plans. The guidance...more
Recent guidance from the Department of Labor (“DOL”), Health and Human Services (“HHS”) and Treasury (the “Departments”) provides limited enforcement relief from the summary of benefits and coverage (“SBC”) disclosure rules...more