News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Employer Group Health Plans Benefit Plan Sponsors

BCLP

Closing the Gap: Health and Welfare Compliance

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Even the most well-managed employee benefit plans may have certain compliance blind spots. From outdated documentation to missed filing deadlines, we have highlighted a few areas below where we often see gaps....more

Mayer Brown

United States: Health and Welfare Hot Topics

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At A Glance - In recent months, there have been a number of important developments in the United States relating to health and welfare plans. This list of hot topics identifies the key areas for employers and plan sponsors to...more

Lathrop GPM

Fifty Years of ERISA

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On Labor Day fifty years ago, September 2, 1974, President Ford signed the Employee Retirement Income Security Act of 1974 (ERISA) into law. It is a combination of tax and labor law incorporating trust law like fiduciary...more

Saul Ewing LLP

A Wellness Check for Your Employee Benefit Plans Part 3: Health and Welfare Surprises

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In the past two weeks, we have presented a few items that plan sponsors can review in hopes of curbing common employee benefits and executive compensation errors.  This week in our Employee Retirement Income Security Act of...more

Bass, Berry & Sims PLC

2023 ERISA Welfare Plan Automatic Participant Disclosures Checklist

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ERISA requires plan sponsors to distribute SPDs to inform participants of their benefits, rights, and obligations under the plan and describe how the plan operates. Department of Labor (DOL) regulations (available here)...more

Patterson Belknap Webb & Tyler LLP

The End of the COVID-19 Emergency Declarations

Today marks the end of the COVID-19 public health emergency that first began on March 13, 2020. The end of the public health emergency has a wide range of implications for employer sponsored benefit plans. This alert...more

Eversheds Sutherland (US) LLP

Preparing employee benefit plans for the emergency exit

The end of an era looms for employee benefits plans, as the Biden administration has announced the end of both the Public Health Emergency and the National Emergency periods on May 11, 2023. The two emergency periods were...more

Davis Wright Tremaine LLP

Agencies Release FAQs Confirming Impact of End of the COVID-19 Emergency Declarations on Employee Benefit Plans

Employers should prepare now for impacts to their employee benefit plans when the COVID-19 Outbreak Period expires. On March 29, 2023, in anticipation of the ends of both the National Emergency and Public Health Emergency,...more

Laner Muchin, Ltd.

COVID National Emergency Ends Early Impacting Health Plans

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On April 10, 2023, President Biden signed a resolution ending the COVID-19 National Emergency. As we had previously reported, the National Emergency originally was scheduled to end on May 11, 2023 – at the same time as the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

No Change in DOL/Treasury Guidance for Employer Health Plans Issued Before Declared End of COVID-19 National Emergency

What does the April 10, 2023, early end of the COVID-19 National Emergency declaration mean for employer health plans? Well, nothing, actually....more

Woodruff Sawyer

Compliance Alert: Agencies Informally Indicate That the Outbreak Period Tied to the COVID-19 National Emergency Ends July 10, 2023

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On April 10, 2023, the President signed H.J.Res. 7, which ended the COVID-19 national emergency on April 10, 2023, approximately one month earlier than anticipated. However, prior to the passage of H.J. Res. 7, the DOL and...more

Woodruff Sawyer

Compliance Alert: Agencies Issue Guidance on the End of COVID-19 Emergencies

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On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to end the COVID-19 national and public health emergencies on May 11, 2023. However, on April 10, 2023, the President...more

Kaufman & Canoles

ESOPs & Employee Benefits Q1 2023 Client Update

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Welcome to Spring! We hope the new season finds you ready for the upcoming benefits changes that 2023 has in store. ...more

Morgan Lewis

COVID-19 Public Health and National Emergencies to End May 11—or Earlier

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With the COVID-19 public health emergency and the presidential declaration of national emergency intended to end on May 11 and the US government recently issuing guidance on unwinding these emergency declarations, this...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers

The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information)....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Employers Prepare for Thawing ERISA Deadlines

With the pandemic winding down, deadlines for employee benefit plans governed by the Employee Retirement Income Security Act (ERISA) will be resuming. Two different emergencies affect employer-sponsored group health plans:...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Medical Travel Reimbursement Benefits Under the Supreme Court’s New Dobbs Decision

On June 24, 2022, the Supreme Court of the United States issued its highly anticipated decision in Dobbs v. Jackson Women’s Health Organization, No. 19-1392. The Dobbs decision expressly overrules the two key precedents that...more

BCLP

Roe Overturned! Meeting Employee Healthcare Needs Post-Roe

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The constitutional right to abortion has been eliminated. The Supreme Court has overturned Roe v. Wade, undoing a federal standard that had legalized abortions since 1973. ...more

Morgan Lewis

Health and Welfare Plan Year-End Reminders

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Permissible Flexibility under Code Section 125 Pursuant to IRS Notice 2021-15 Notice 2021-15 offered plan sponsors the flexibility to adopt any of the following options despite the longstanding rules under Section 125 of the...more

Snell & Wilmer

Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines

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The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985...more

Fisher Phillips

September 15 Deadline Looming for Required ARPA Notices

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The American Rescue Plan Act of 2021 (ARPA) mandates that group health plans that are subject to COBRA must provide coverage to certain assistance eligible individuals (AEI) at no cost for periods of coverage between April 1,...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

It’s Not Over ‘Til It’s Over: The COBRA Premium Subsidy is Ending

As we mentioned in our May 23, 2021, article, the American Rescue Plan Act of 2021 (ARPA) provides a 100 percent premium subsidy for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA)...more

Fisher Phillips

IRS Provides Further Clarity to Employers on Stimulus Tax Credits

Fisher Phillips on

The Internal Revenue Service recently released a Notice to further explain its position on certain issues related to the COBRA premium assistance and corresponding tax credits available under the American Rescue Plan Act of...more

Harris Beach Murtha PLLC

Reminder: Don’t Forget to Timely Furnish the Required Notice of Expiration of the ARP COBRA Premium Subsidy Period!

The American Rescue Plan Act of 2021 (the ARP, enacted on March 11, 2021) provides a temporary 100% COBRA premium subsidy to any assistance eligible individual (AEI) who loses employer-sponsored group health coverage due to a...more

Snell & Wilmer

Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act

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The American Rescue Plan Act (“ARPA”) has been the law of the land since March 11, 2021. Even so, many questions remained unanswered with respect to ARPA’s impact on group health plans. To resolve some of the lingering...more

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