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One Court Permits Tobacco Premium Surcharge Claims to Proceed Beyond the Pleading Stage, While Dispositive Motions Remain Pending...

In fall 2024, plaintiffs filed a wave of putative class action lawsuits against employers challenging wellness programs that impose a health coverage premium surcharge on participants if they do use tobacco or do not complete...more

IRS Guidance Sheds Light on COBRA Premium Payment Deadlines in the Time of COVID-19

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

IRS Uncoils COBRA Subsidy Guidance!

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

DOL Issues Cybersecurity Guidance for Plan Sponsors, Plan Fiduciaries, Recordkeepers, and Plan Participants

On April 14, 2021, the U.S. Department of Labor (“DOL”) issued a cybersecurity guidance package directed to plan sponsors; fiduciaries regulated under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”);...more

DOL Takes First Bite At COBRA Subsidy Guidance

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

Congress Finalizes COVID-19 Legislation With Health, Tax, and Retirement Changes

On March 10, 2021, the House of Representatives passed the version of the American Rescue Plan Act (H.R. 1319, the “Act”) previously passed by the Senate on March 6. President Biden is expected to sign the legislation on...more

DOL Issues Guidance on Outbreak Period Extensions – With 2 Days to Spare!

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

Breaking Down the “Outbreak Period” Extensions: The Clock May Begin Ticking Soon for Important Deadlines Suspended Due to COVID-19

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

EEOC Releases Much-Anticipated Proposed ADA and GINA Wellness Rules

On January 7, 2021, the Equal Employment Opportunity Commission (“EEOC”) finally released proposed rules regarding wellness programs under Title I of the Americans with Disabilities Act (“ADA”) (“ADA Proposed Rule”) and Title...more

Employers Get Bit: Flurry of Class Action Lawsuits Allege Deficiencies in COBRA Election Notices

Recently, plaintiffs’ firms have filed a flurry of class action lawsuits against employers, alleging violations of COBRA’s election notice requirements and seeking statutory and other penalties. ...more

DOL & Treasury Extend ERISA-Required Deadlines, Creating Questions & Disruptions in Administrative Procedures

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

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