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Employer Group Health Plans Premium Subsidies

Lowenstein Sandler LLP

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

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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

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

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

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

Morgan Lewis - ML Benefits

IRS Provides Second Round of FAQs on COBRA Subsidies

As we get closer to the September 30 expiration date of the COBRA premium subsidy provided under the American Rescue Plan Act (ARPA), the IRS has issued a second set of FAQs in Notice 2021-46 (Notice) to supplement its prior...more

Eversheds Sutherland (US) LLP

COBRA subsidy strikes again with IRS guidance in Notice 2021-31

The American Rescue Plan Act (the Act) included certain temporary COBRA subsidy provisions that allow “Assistance Eligible Individuals” (AEIs) to receive COBRA subsidies from April 1, 2021 to September 30, 2021 (the...more

Proskauer - Employee Benefits & Executive...

Calculating the ARP COBRA Premium Subsidy Tax Credit

On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice...more

Snell & Wilmer

Subsidized COBRA Elections under ARPA Override COBRA Election Deadline Extensions

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As detailed in our SW Benefits Update, “Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act,” the IRS recently released Notice 2021-31 (the “Notice”), providing welcome...more

Patterson Belknap Webb & Tyler LLP

IRS Publishes Detailed Guidance Relating to ARPA COBRA Premium Assistance

On May 18, 2021, the Internal Revenue Service (“IRS”) published Notice 2021-31 (the “IRS Notice”) containing detailed guidance relating to premium assistance for COBRA benefits under the American Rescue Plan Act of 2021...more

Proskauer - Employee Benefits & Executive...

All Good Subsidies Must Come to an End, Part II: The IRS Adds Some Nuances

In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice.  This post revisits the topic in light of...more

Snell & Wilmer

Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act

Snell & Wilmer on

The American Rescue Plan Act (“ARPA”) has been the law of the land since March 11, 2021. Even so, many questions remained unanswered with respect to ARPA’s impact on group health plans. To resolve some of the lingering...more

McDermott Will & Emery

How to Apply the IRS’s COBRA Premium Subsidy Guidance

On May 18, 2021, the Internal Revenue Service (IRS) issued much-anticipated Notice 2021-31 (the Notice) regarding the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy provisions of the American Rescue...more

Dickinson Wright

IRS Guidance on COBRA Subsidy, Part III: Claiming the Premium Assistance Credit

Dickinson Wright on

Under the American Rescue Plan Act of 2021 ("ARPA"), a 100% COBRA subsidy is available to qualified beneficiaries who lose coverage due to an involuntary termination of employment or reduction in hours. The subsidy is...more

Bradley Arant Boult Cummings LLP

IRS Guidance Clarifies “Involuntary Termination” for the COBRA Subsidy

In Notice 2021-31, the Internal Revenue Service (IRS) provides broad guidance in a question-and-answer format on the application of the American Rescue Plan Act of 2021 (ARP) regarding premium assistance under the...more

Proskauer - Employee Benefits & Executive...

Guide to New IRS Guidance on COBRA Premium Subsidy

On May 18, 2021, the IRS released Notice 2021-31, which provides implementation guidance on the COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARP). As discussed in our prior blog posts, ARP...more

Alston & Bird

IRS Provides 86 Answers to 86 Questions About the COBRA Subsidy

Alston & Bird on

Our Employee Benefits & Executive Compensation Group summarizes the IRS’s 86 Q&As about the COBRA premium assistance subsidy and offers takeaways employers can use to guide their path ahead of the May 31 deadline....more

Lowenstein Sandler LLP

IRS Issues COBRA Subsidy Guidance

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On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA), which provides temporary premium assistance for health, dental, and vision coverage under the Consolidated Omnibus Budget...more

Faegre Drinker Biddle & Reath LLP

IRS Guidance on New COBRA Subsidy Clarifies Many Outstanding Questions

On May 18, 2021, the IRS released Notice 2021-31, a lengthy series of FAQs clarifying many aspects of the new COBRA subsidy made available under the American Rescue Plan Act of 2021 (ARPA). The FAQs address many of the issues...more

Jackson Walker

American Rescue Plan Act’s COBRA Premium Assistance – A New Ball Game and New Rules

Jackson Walker on

The Internal Revenue Service has provided additional guidance on the the American Rescue Plan Act’s COBRA premium assistance. Greta Cowart summarizes the top 10 takeaways of Notice 2021-31 specifically related to group health...more

Verrill

ARPA Premium Subsidy: Long-Awaited Details Finally Arrive

Verrill on

The IRS recently issued Notice 2021-31, which provides much sought-after detail regarding the contours and operation of the temporary premium subsidy for COBRA continuation coverage available through the American Rescue Plan...more

Epstein Becker & Green

IRS Guidance on ARPA COBRA Subsidies: 86 Q&As and Counting

Epstein Becker & Green on

As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”) into law on March 11, 2021, which, among other things, mandates that employers provide 100 percent COBRA premium subsidies to eligible...more

Akin Gump Strauss Hauer & Feld LLP

COBRA Premium Subsidy under the American Rescue Plan Act of 2021 and IRS Notice 2021-31

On May 18, 2021, the Internal Revenue Service (IRS) released Notice 2021-31 (the “Notice”) providing guidance in Q&A format on the application of the temporary COBRA premium assistance provisions of the American Rescue Plan...more

Jackson Lewis P.C.

IRS Provides Clarity On ARPA COBRA Subsidy Impact On State “Mini-COBRA” Plans

Jackson Lewis P.C. on

In our most recent summary of IRS Notice 2021-31, we noted the Internal Revenue Service provided much-needed clarity to looming compliance challenges as employers, insurers, and others race to implement the applicable COBRA...more

Fisher Phillips

IRS Addresses Lingering Employer Questions Regarding COBRA Premium Assistance and Corresponding Tax Credits under the American...

Fisher Phillips on

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

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