News & Analysis as of

Notice Requirements Premium Subsidies Internal Revenue Service

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

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

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

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

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

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

Perkins Coie

Employer Responsibilities Under the ARPA COBRA Subsidy

Perkins Coie on

The American Rescue Plan Act of 2021 (ARPA) includes a number of provisions requiring immediate action by employers. One such provision provides for a 100% federal subsidy of COBRA premiums (including the up-to-2%...more

Latham & Watkins LLP

US Stimulus Creates Temporary COBRA Premium Subsidy and Payroll Tax Credit

Latham & Watkins LLP on

Under the new stimulus law, employers must make available temporary COBRA premium subsidies and special COBRA enrollment rights to eligible individuals. Employers are entitled to a refundable payroll tax credit for the amount...more

Miller Canfield

American Rescue Plan Act Brings Back COBRA Subsidies, Prompt Action Needed

Miller Canfield on

The American Rescue Plan Act of 2021 (the "ARPA") brings back COBRA subsidies (previously available in modified form under the American Recovery and Reinvestment Act of 2009) starting April 1, 2021, and requires employers and...more

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