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Sept. 15 Is Final Deadline for ARPA COBRA Subsidy Expiration Notices

Section 9501 of the American Rescue Plan Act of 2021 (“ARPA”) requires employers, multiemployer trustees and insurers (collectively, “plan administrators”) to provide a 100% subsidy for COBRA health care continuation coverage...more

What Is An Involuntary Termination Or Reduction In Hours For ARPA COBRA Premium Assistance?

One of the first questions that must be addressed in order to determine whether an individual is eligible for the temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes)...more

Will Biden’s American Families Plan Take Aim at Executive Compensation?

There already has been a lot of discussion about the elements anticipated to be part of President Joe Biden’s American Family Plan, including some of the tax increases being considered to pay for the proposed “human...more

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

No Fooling Around: New Six-Month COBRA Subsidy Starts April 1, Requires Immediate Action

The American Rescue Plan Act of 2021 (“ARPA”) includes a temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes) to “assistance eligible individuals” (“AEIs”). This...more

Democrats Unveil COVID-19 Bill Text Ahead of Markup

On Feb. 8, House Ways and Means Committee Chair Richard Neal (D-MA) released text representing its portion of Democrats’ $1.9 trillion COVID-19 stimulus legislation, modeled after President Joe Biden’s American Rescue Plan....more

Have You Thought About ... Who Will Pay for COVID-19 Testing for Employees?

A common misconception has evolved that all COVID-19 testing is free for individuals. In actuality, only certain COVID-19 testing is free for an individual: (1) testing covered 100% by a health plan or issuer and (2) testing...more

President Trump's Aug. 8 Tax Executive Orders

On Saturday, Aug. 8, 2020, President Donald Trump signed four executive orders (EO) to defer payroll taxes, set up an assistance program for lost wages to supplement unemployment benefits, extend the federal moratorium on...more

HEALS Act Comparison to HEROES Act and Current Law

On Monday, July 27, Senate Majority Leader Mitch McConnell (R-KY) released the Health, Economic Assistance, Liability and Schools (HEALS) Act—a $1 trillion stimulus package in response to the ongoing effects of the COVID-19...more

PBGC Q&As: Impact of COVID-19 and CARES Act on Single-Employer Pension Plans

The Pension Benefit Guaranty Corporation (“PBGC”) has posted questions and answers (“Q&As”) related to the impact that COVID-19 and the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136 (March 27, 2020) (the...more

IRS Guidance on 2020 RMD Waivers Includes Rapidly Approaching Rollover Deadline

Two significant changes affecting required minimum distributions under Section 401(a)(9) of the Internal Revenue Code have been made in the most recent two years...more

FAQs Part 43: Guidance on Health Coverage Issues Related to COVID-19

The HHS, DOL and IRS have released additional guidance in the form of frequently asked questions (FAQs) regarding health coverage issues related to the 2019 novel coronavirus (“COVID-19”),1 including under the Families First...more

Have You Thought About … How State and Local Income Tax and Employment Laws Apply to Remote Workers During COVID-19? (Part 2)

COVID-19 has drastically changed how and where employees work. Many employees are now temporarily working from their homes or other remote locations. These temporary (and potentially longer-term) telecommuting arrangements...more

Have You Thought About … How State and Local Income Tax and Employment Laws Apply to Remote Workers During COVID-19? (Part 1)

COVID-19 has drastically changed how and where employees work. Many employees are now temporarily working from their homes or other remote locations. These temporary (and sometimes longer-term) telecommuting arrangements...more

IRS Notice 2020-50: Guidance on Coronavirus Related Distributions and Loans

The Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136 (the “CARES Act”) became law on March 27, 2020. For information about the CARES Act, please see our summary. Among other things, Section 2202 of the...more

Have You Thought About ... Who Will Pay for Asymptomatic Carrier Testing?

In order to safely reopen businesses, many employers plan to use COVID-19 testing to ensure that employees who are physically present in the workspace are healthy. Absent a vaccine or widespread immunity, COVID-19 carrier...more

Have You Thought ... How Reopening Affects Your Bonus, Equity-Based and Deferred Compensation Plans?

As employers start to reopen and bring employees back to work, bonus programs (such as short-term and long-term bonuses), equity-based compensation arrangements (such as restricted stock, stock options and phantom equity),...more

Now on the COVID-19 Menu: Temporary Flexibility for Cafeteria Plans

With the 2019 novel coronavirus (“COVID-19”) national health emergency continuing, employers are continuing to try to find ways to help their employees. In response to requests from employers, the Internal Revenue Service...more

Analysis of Economic Provisions in HEROES Act

On May 12, House Democrats unveiled the Health and Economic Recovery Omnibus Emergency Solutions Act (HEROES) Act. Democratic leadership intends to bring the legislation to the floor for a vote on Friday. The bill is the...more

Key Issues to Consider While Reopening or Partially Reopening

As state and local governments relax their “stay-at-home” orders, businesses must look at how to revamp and reinvent their day-to-day operations to comply not only with a wide variety of new regulations, but also legal...more

For Whom the Timing Tolls: The COVID-19 Outbreak Period Interrupts Benefit Plan Deadlines

New employee benefits guidance temporarily extends certain time frames and deadlines for participant actions and relieves some plan administration compliance obligations during the COVID-19 National Emergency (the “COVID-19...more

Analysis of Senate-Passed CARES Act

On March 25, the Senate approved a $2 trillion stimulus package, the Coronavirus Aid, Relief, and Economic Security Act, to address the economic and health impacts of the COVID-19 pandemic. The bill now moves to the House for...more

How Employers Can Assist Employees (Current and Former) Right Now

Countless employers have been forced to reduce employees’ hours or terminate employees due to the 2019 novel coronavirus (“COVID-19”). Federal and state governments are working to pass stimulus legislation to assist the...more

Health Plan Coverage of Coronavirus Testing and Treatment

With the news about the spread of the 2019 novel coronavirus (“COVID-19”) in the U.S. and the world rapidly evolving, group health plan sponsors need to address how the plan will provide virus-related benefits. ...more

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