News & Analysis as of

Notice Requirements Consolidated Omnibus Budget Reconciliation Act American Rescue Plan Act of 2021

Laner Muchin, Ltd.

Reminder: Employers Have Until September 15 to Issue COBRA Subsidy Termination Notices

Laner Muchin, Ltd. on

As previously reported, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA payments for a COBRA qualified beneficiary who becomes eligible for COBRA due to a reduction in hours or involuntary...more

Fisher Phillips

September 15 Deadline Looming for Required ARPA Notices

Fisher Phillips on

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

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

Williams Mullen

COBRA Subsidy Expiration Notice is Due September 15

Williams Mullen on

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

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

BCLP

Are Your COBRA Notices Sufficient to Avert a Costly Challenge?

BCLP on

While the Consolidated Omnibus Budget Reconciliation Act (“COBRA”) continuation coverage subsidy requirements imposed by the American Rescue Plan Act of 2021 are at the forefront of employers’ minds, recent litigation trends...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

Lowenstein Sandler LLP

IRS Issues COBRA Subsidy Guidance

Lowenstein Sandler LLP on

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

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

COBRA Subsidy: You’ve Got Questions...We’ve Got Answers

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

Goodwin

American Rescue Plan: How to Navigate New Continuation Coverage Standards for COBRA

Goodwin on

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA” or the “Act”), the latest COVID-19 relief bill, into law. Under ARPA, employers will generally be obligated to advance the cost of...more

Vinson & Elkins LLP

DOL Releases Temporary COBRA Subsidy Guidance For Employers

Vinson & Elkins LLP on

The Department of Labor (“DOL”) issued new guidance earlier this month on the temporary COBRA subsidies provided by the recently enacted American Rescue Plan Act (the “ARP”), which employers may find useful in administering...more

Proskauer - Employee Benefits & Executive...

All Good Subsidies Must Come to an End: ARP’s Expiration Notice Requirements

As mentioned in our earlier posts, the American Rescue Plan Act of 2021 (“ARP”) provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible...more

Smith Anderson

ARPA COBRA Subsidy's Impact on Employer Health Plans

Smith Anderson on

The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more

Brooks Pierce

Availability of Health Insurance Subsidy Requires Employers to Act

Brooks Pierce on

On March 11, 2021, President Biden signed the American Rescue Plan Act (“ARPA” or the “Act”), another piece of the federal government’s response to the COVID-19 pandemic. Among other things, the Act provides premium...more

Parker Poe Adams & Bernstein LLP

U.S. Labor Department Answers Some - But Not All - Key Questions About New COBRA Subsidies

As previously reported in EmployNews, the American Rescue Plan Act provides “assistance eligible individuals” with the option to receive fully-subsidized COBRA coverage from April 1, 2021 through September 30, 2021....more

Patterson Belknap Webb & Tyler LLP

American Rescue Plan Act: New Guidance on COBRA Premium Assistance

The American Rescue Plan Act (“ARPA”) became law in March of this year. One of the many relief provisions included in ARPA is a temporary subsidy of COBRA continuation premiums for certain individuals, summarized in our...more

Fox Rothschild LLP

Department Of Labor Issues Guidance, Model Notices For COBRA Premium Subsidies Under The American Rescue Plan Act

Fox Rothschild LLP on

On April 7, 2021, the U.S. Department of Labor (DOL) issued much needed guidance to employers and their COBRA administrators on the “COBRA premium subsidy” provision of the American Rescue Plan Act (ARPA). This provision...more

Clark Hill PLC

New COBRA Notices Must Be Issued by May 31

Clark Hill PLC on

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

Faegre Drinker Biddle & Reath LLP

DOL Issues Model COBRA Subsidy Notices and Initial Guidance on COBRA Subsidy Relief under the American Rescue Plan Act of 2021

As discussed in our prior blog post, the American Rescue Plan Act of 2021 (ARP) requires employers that sponsor group health plans to provide a 100% COBRA subsidy for “Assistance Eligible Individuals” during the “Subsidy...more

ArentFox Schiff

DOL Issues Model Notices For COBRA Subsidy Under American Rescue Plan Act

ArentFox Schiff on

The subsidized premiums are available from April 1, 2021, through September 30, 2021 (the “Premium Assistance Period”), unless earlier terminated as discussed below. The Department of Labor (DOL) was charged with...more

Foley & Lardner LLP

Overview of New DOL Guidance for the COBRA Subsidy Mandate – Including Helpful Charts Summarizing New Notice Requirements

Foley & Lardner LLP on

Takeaway Message. The Department of Labor (“DOL”) has recently issued model notices and forms that can be used to comply with the new subsidized COBRA requirements created by the American Rescue Plan Act of 2021 (“ARPA” or...more

Miles & Stockbridge P.C.

Part III: DOL Releases Model Notices for Mandatory COBRA Premium Subsidy

Under the American Rescue Plan Act of 2021 (ARPA), which was passed by Congress on March 11, 2021, the cost of health insurance coverage pursuant to the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) is...more

Foley Hoag LLP

DOL Releases Model COBRA Notices to Satisfy Employer Obligations Under ARPA

Foley Hoag LLP on

On April 7, 2021, the Department of Labor (“DOL) released a series of Frequently Asked Questions with clarifying information about the American Rescue Plan Act of 2021’s (“ARPA”) extended subsidy period for COBRA premium...more

BCLP

DOL Flies Alone: Guidance on the 100% COBRA Subsidy under the American Rescue Plan Act of 2021

BCLP on

The American Rescue Plan Act of 2021 (“ARPA”) provides that, for the period from April 1, 2021 until September 30, 2021, if an individual’s Consolidated Omnibus Budget Reconciliation Act (“COBRA”) qualifying event is an...more

Saul Ewing LLP

Guidance Issued on Implementation of ARPA COBRA Premium Subsidy

Saul Ewing LLP on

Group health continuation coverage under the Consolidated Omnibus Reconciliation Act of 1985 (“COBRA”) permits certain group health coverage to be continued by participants and beneficiaries (“qualified beneficiaries”) when...more

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