On June 23, 2023, the IRS issued Notice 2023-37 (the “2023 Notice”) regarding COVID-19-related coverage for HSA-compatible high-deductible health plans (“HDHPs”) and preventive care for HDHP purposes in light of the district...more
On December 2, 2021, President Biden announced new actions to combat COVID-19, given the emergence of the new Omicron variant. As part of his nine-point plan, the President included a directive that “the more than 150...more
On December 2, 2021, President Biden announced new actions to combat COVID-19, given the emergence of the new Omicron variant. As part of his nine-point plan, the President included a directive that “the more than 150...more
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
With rising rates of COVID-19 cases in the past few months, employers have been increasingly interested in exploring incentives designed to increase COVID-19 vaccination rates among employees. One idea that has been gaining...more
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
Since the American Rescue Plan Act (“ARPA”) was enacted in March 2021, employers and insurers have been diligently familiarizing themselves with the rules for administering the temporary 100% COBRA premium subsidy established...more
On May 18, 2021, the IRS released its highly anticipated guidance on the 100% COBRA premium subsidies (the “Subsidy”) and the related tax credit under the American Rescue Plan Act of 2021 (March 11, 2021) (“ARPA”) in Notice...more
Federal legislation and related administrative guidance enacted and issued in response to the US COVID-19 pandemic have relaxed certain requirements that otherwise apply to some health and welfare plan arrangements. This...more
On April 7, 2021, the Department of Labor (“DOL”) released initial guidance regarding the 100% COBRA premium subsidies under the American Rescue Plan Act of 2021 (“ARP”), and also issued model notices that can be used in...more
In the early morning hours of February 27, the House of Representatives narrowly passed H.R. 1319, the American Rescue Plan Act (the “Rescue Plan”), by a vote of 219-212. The Senate will now take up the sweeping $1.9 trillion...more
On February 17th, we posted an alert that the COVID-19 extensions that the DOL and IRS had issued last year as part of their “Joint Notice” were set to expire at midnight on February 28th. For weeks, we have been asking DOL...more
As the COVID-19 pandemic began to overwhelm the country last spring, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) became concerned that the disruption caused by the pandemic would create...more
On December 21, the House and Senate passed a $2.3 trillion omnibus appropriations and COVID-19 relief package, H.R. 133, the Consolidated Appropriations Act, 2021 (the “Act”). President Trump signed the Act into law on...more
The IRS released two Notices this week related to cafeteria plans and flexible spending arrangements (“FSAs”). Notice 2020-29 provides relief for cafeteria plans in response to the current COVID-19 pandemic, and Notice...more
On April 29, 2020, the Departments of Labor (“DOL”) and Treasury (together, the “Departments”) issued guidance extending certain deadlines related to retirement, health, and welfare plans in response to the current COVID-19...more
5/6/2020
/ COBRA ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Filing Deadlines ,
Health and Welfare Plans ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
Relief Measures ,
U.S. Treasury
In the face of the unprecedented COVID-19 pandemic, many employees may experience financial hardship. For example, they may incur unexpected expenses as a result of COVID-19, including being quarantined or under a stay at...more
On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). ...more