News & Analysis as of

Premium Subsidies Health and Welfare Plans

Pullman & Comley - Labor, Employment and...

COBRA Update: Final COBRA Subsidy Termination Notices Now Due

As mentioned in our prior COBRA update, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA premium payments. The subsidy is available to COBRA qualified beneficiaries who become eligible for COBRA...more

Akerman LLP - HR Defense

Deadline Triggered as COBRA Premium Subsidy Ends

Employers and plans are reminded that they must provide a COBRA subsidy expiration notice no later than September 15, 2021, pursuant to the American Rescue Plan Act of 2021 (ARPA). ARPA had included some new COBRA obligations...more

Stinson LLP

COBRA Premium Assistance Expiration Notice Deadline Approaching

Stinson LLP on

The COBRA premium assistance period, as part of the American Rescue Plan Act, will expire on September 30, 2021. Plans are required to send notices to assistance eligible individuals (AEIs) to inform them about the subsidy's...more

Morgan Lewis

IRS Issues Guidance Regarding American Rescue Plan Act COBRA Subsidy

Morgan Lewis on

The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more

McNees Wallace & Nurick LLC

Good News and Bad News: The IRS Issues 86 Q&A’s on the ARP COBRA Subsidy

On May 18, 2021, the IRS issued the long- awaited guidance on the COBRA subsidy and premium assistance credit available under the American Rescue Plan Act of 2021 through eighty-six questions and answers....more

Robinson & Cole LLP

IRS Clarifies Key Provisions of the COBRA Subsidy

Robinson & Cole LLP on

As anticipated, the Internal Revenue Service (IRS) issued Notice 2021-31 (the Notice) yesterday, providing important guidance to employers and plan administrators regarding their COBRA subsidy-related obligations under the...more

Akerman LLP - HR Defense

Deadline Looms to Notify Current and FORMER Employees of COBRA Premium Subsidy

Employers, if you had employees who had been on your group health plan who were involuntarily terminated or whose hours were reduced as early as November 1, 2019, read this! If those employees became eligible for COBRA and...more

FordHarrison

The IRS Releases FAQ Guidance on Premium Assistance for COBRA Coverage

FordHarrison on

On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 which contains much anticipated guidance needed to implement the COBRA subsidy provisions included in the American Rescue Plan Act of 2021 (ARPA)....more

WilmerHale

COVID-19: COBRA Subsidy Under the American Rescue Plan Act of 2021 - Important Deadlines Approaching

WilmerHale on

On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARPA), which subsidizes fully paid post-employment healthcare coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA)...more

Robinson & Cole LLP

No Time to Waste: Employer Action Needed for COBRA Subsidy Administration

Robinson & Cole LLP on

The COBRA subsidy period (April 1, 2021 – September 30, 2021) has begun and with a number of issues still outstanding, employers have no time to lose when it comes to preparing to administer the COBRA subsidy required by the...more

Lippes Mathias LLP

New COBRA Coverage Obligations for Employers

Lippes Mathias LLP on

Notice To Employers And Group Health Plans – New COBRA Continuation Coverage Obligations And Premium Subsidies Under The American Rescue Plan Act Of 2021....more

Clark Hill PLC

ARPA Provides for Full COBRA Premium Subsidies

Clark Hill PLC on

On March 11, 2021, the American Rescue Plan Act of 2021 (the “ARPA”) was signed into law. Under Section 9501 of ARPA, employers will be required to provide a tax-free subsidy to certain employees and their qualified...more

Akerman LLP - HR Defense

ARPA COBRA Premium Subsidy – Time for Employer Plans to Update COBRA Notices

Employers should be busy preparing tailored COBRA continuation coverage notices for certain individuals, addressing complicated election and altered COBRA premium topics that took effect only in recent weeks. Below, we offer...more

Polsinelli

Department of Labor Provides Model Subsidized COBRA Notices and Additional Guidance

Polsinelli on

As described in our March 15, 2021 update, the American Rescue Plan Act of 2021 (the “Act”) created a temporary, 100% subsidy for assistance-eligible individuals’ premium payments for continuation health care coverage under...more

Bodman

Workplace Law Lowdown | The American Rescue Plan: Employer Takeaways

Bodman on

President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law on March 11, 2021. Provided here is an overview of the key features that affect employers....more

McNees Wallace & Nurick LLC

DOL Issues Guidance On And Model Notices For ARPA’S COBRA Subsidy

The Department of Labor recently issued FAQs addressing basic questions regarding the American Rescue Plan Act’s requirement that employers and health plans subsidize COBRA between April 1, 2021 and September 30, 2021 for...more

Verrill

Identifying Plan Assets in ERISA Health & Welfare Plans

Verrill on

Last month, we advised readers of this blog to consider efforts to formalize the fiduciary governance of their health and welfare benefit plans. In that post, we described some of the reasons that employers have historically...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

Schwabe, Williamson & Wyatt PC

Fully Subsidized COBRA Under the American Rescue Plan Act

The American Rescue Plan Act of 2021 (ARPA) requires fully subsidized COBRA premium payments for assistance eligible individuals beginning as early as April 1, 2021, and ending as late as September 30, 2021 (the Subsidy...more

Akerman LLP - HR Defense

New COBRA Obligations for Employers Included in Biden’s $1.9 Trillion Stimulus

For employers with group health plans, COBRA obligations under President Biden’s premiere $1.9 trillion stimulus legislation, the American Rescue Plan Act of 2021 (the “Rescue Plan”) are an early priority. ...more

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