News & Analysis as of

Internal Revenue Service Premium Subsidies

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Woods Rogers

Does the Fun Ever Stop? COVID-19 Tolling Ends for COBRA Deadlines

Woods Rogers on

On April 10, 2023, President Biden signed legislation to end the COVID-19 national emergency effective immediately, including ending the requirement to extend COBRA deadlines due to the COVID-19 pandemic. Plan administrators...more

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

Ballard Spahr LLP

IRS Issues New Guidance on COBRA Deadline Extensions

Ballard Spahr LLP on

The IRS (with the concurrence of the DOL and HHS) has issued new guidance explaining how the extension of the deadline for paying COBRA premiums will be applied. ...more

Seyfarth Shaw LLP

We Have No Idea When The Outbreak Period Will End, But We Have a Better Idea When COBRA Payments are Due

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS has attempted to provide clarity (following the DOL’s earlier attempt) on how the coronavirus Outbreak Period will work and how it applies  to COBRA election and premium payment deadlines, in Notice...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

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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

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

Morgan Lewis - ML Benefits

American Rescue Plan Act of 2021 COBRA Subsidy Expiration Notice Is Due

The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy for up to six months, from April 1, 2021 through September 30, 2021, for Assistance Eligible Individuals (AEIs) as defined under the...more

Seyfarth Shaw LLP

Never Fear: More COBRA Subsidy Guidance Is Here

Seyfarth Shaw LLP on

On July 26, 2021, the U.S. Internal Revenue Service (“IRS”) issued Notice 2021-46, providing additional guidance on the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) and premium assistance and tax credit...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

Ballard Spahr LLP

COBRA Premium Subsidies - A Little More Guidance (and a Reminder)

Ballard Spahr LLP on

The IRS issued a new notice that provides guidance on a few issues that were not fully addressed in its earlier notice on the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy requirements set forth in...more

Groom Law Group, Chartered

IRS Releases New COBRA Subsidy Guidance . . . With Less Than A Week Until Forms 941 Are Due!

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

Proskauer - Employee Benefits & Executive...

An Additional Word from IRS Regarding the ARP COBRA Subsidy

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

Proskauer - Employee Benefits & Executive...

A Practical Guide to Claiming the COBRA Premium Assistance Tax Credit

Over the last few months, employers and plan administrators have concentrated on identifying qualifying individuals eligible for COBRA premium assistance under the American Rescue Plan Act of 2021 (“ARP”), sending out proper...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

Proskauer - Employee Benefits & Executive...

A Word from the IRS on Involuntary Terminations of Employment for Purposes of the ARP COBRA Premium Subsidy

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

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

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

Bond Schoeneck & King PLLC

IRS Issues Comprehensive Guidance Regarding ARPA COBRA Subsidy

June 1, 2021 By: Lawrence J. Finnell On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 (Notice) which provides additional guidance and clarifications concerning the new COBRA premium assistance...more

Stinson - Benefits Notes Blog

IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA

On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by 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

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