News & Analysis as of

Notice Requirements Consolidated Omnibus Budget Reconciliation Act Employer Group Health Plans

McDermott Will & Emery

Takeaways from a Recent COBRA Notice Class Action Settlement

Recent years have seen a barrage of class action lawsuits alleging that group health plan continuation coverage election notices, required under the Consolidated Omnibus Budget Reconciliation Act (COBRA), are deficient in one...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

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

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

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

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

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

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

Laner Muchin, Ltd.

New DOL Guidance and Model Notices Assist Employers with Their New COBRA Subsidy Obligations

Laner Muchin, Ltd. on

As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more

Nelson Mullins Riley & Scarborough LLP

COBRA Subsidies are Revived — Update

The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs or had a reduction in hours (and their family...more

Williams Mullen

DOL Issues Model Notices and FAQs for COBRA Subsidy

Williams Mullen on

As described in our previous alert, the American Rescue Plan Act of 2021 (the ARPA), provides a full subsidy for COBRA premiums for certain qualified beneficiaries entitled to COBRA continuation coverage from April 1, 2021,...more

Stokes Wagner

Employers Should Begin Planning for COBRA Subsidy

Stokes Wagner on

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

Brownstein Hyatt Farber Schreck

ARPA COBRA Subsidy Model Notices and Guidance Released Today Requires Immediate Action

Ahead of its April 11, 2021 deadline, the U.S. Department of Labor (“DOL”) has issued some guidance and model notices related to the temporary 100% subsidy for COBRA health care continuation coverage (including under state...more

Fenwick & West LLP

March 2021 Employment Law Update: New ARPA/COBRA Subsidy, COVID-19-Related Sick Leave Developments and More

Fenwick & West LLP on

New ARPA/COBRA Subsidy - The federal American Rescue Plan Act of 2021 (ARPA) provides for a 100% subsidy of COBRA premiums for six months from April 1, 2021 through September 30, 2021, for individuals (and their covered...more

Holland & Knight LLP

COBRA Premium Subsidy Under the American Rescue Plan Act

Holland & Knight LLP on

The recently signed American Rescue Plan Act (ARPA) will have a major impact during the next six months on employers' obligations and considerations in administering COBRA health insurance benefits. Subtitle F of ARPA –...more

Partridge Snow & Hahn LLP

Employers Should Brace Themselves for the ARPA's Burdensome Paid COBRA Mandate

On March 11, 2021, President Biden signed into law a $1.9 trillion stimulus bill, the American Rescue Plan Act of 2021 (ARPA). The reach of the ARPA extends far and wide, including to healthcare coverage available to...more

Miles & Stockbridge P.C.

Part II: The American Rescue Plan Act Requires Employers to Fully Subsidize COBRA for Six Months

The American Rescue Plan Act of 2021, signed on March 11, 2021, requires employers to fully subsidize COBRA for certain eligible individuals. Eligible individuals consist of employees and their spouses and dependents who lost...more

Constangy, Brooks, Smith & Prophete, LLP

American Rescue Plan Act -- COBRA Strikes

Now you know. The American Rescue Plan Act has made some important changes to the obligations of employer-sponsored health plans under the Consolidated Omnibus Budget Reconciliation Act, better known as COBRA...more

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