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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 From outdated documentation to missed filing deadlines, we have highlighted a few areas below where we often see gaps....more
Recent years have seen a barrage of class action lawsuits alleging that group health plan continuation coverage election notices, required under the Consolidated Omnibus Budget Reconciliation Act (COBRA), are deficient in one...more
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
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
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
In Notice 2021-31, the Internal Revenue Service (IRS) provides broad guidance in a question-and-answer format on the application of the American Rescue Plan Act of 2021 (ARP) regarding premium assistance under the...more
On March 11, President Biden signed into law the American Rescue Plan Act of 2021 (ARPA), which provides temporary premium assistance for health, dental, and vision coverage under the Consolidated Omnibus Budget...more
The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it...more
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA” or the “Act”), the latest COVID-19 relief bill, into law. Under ARPA, employers will generally be obligated to advance the cost of...more
The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more
As previously reported in EmployNews, the American Rescue Plan Act provides “assistance eligible individuals” with the option to receive fully-subsidized COBRA coverage from April 1, 2021 through September 30, 2021....more
The American Rescue Plan Act (“ARPA”) became law in March of this year. One of the many relief provisions included in ARPA is a temporary subsidy of COBRA continuation premiums for certain individuals, summarized in our...more
On April 9, the U.S. Department of Labor (DOL) issued new guidance about the COBRA subsidy available under the American Rescue Plan Act (ARPA). Employers subject to COBRA must send out the updates notices as soon as possible...more
As discussed in our prior blog post, the American Rescue Plan Act of 2021 (ARP) requires employers that sponsor group health plans to provide a 100% COBRA subsidy for “Assistance Eligible Individuals” during the “Subsidy...more
Under the American Rescue Plan Act of 2021 (ARPA), which was passed by Congress on March 11, 2021, the cost of health insurance coverage pursuant to the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) is...more
On April 7, 2021, the U.S. Department of Labor (DOL) issued welcome guidance - including eagerly-anticipated model notices - to help employers and their COBRA administrators implement the temporary six-month (April 1 to...more
The American Rescue Plan Act of 2021 (“ARPA”) provides that, for the period from April 1, 2021 until September 30, 2021, if an individual’s Consolidated Omnibus Budget Reconciliation Act (“COBRA”) qualifying event is an...more
Group health continuation coverage under the Consolidated Omnibus Reconciliation Act of 1985 (“COBRA”) permits certain group health coverage to be continued by participants and beneficiaries (“qualified beneficiaries”) when...more
As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more
The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, (“ARPA”) includes generous provisions granting eligible individuals who have lost their jobs or had a reduction in hours (and their family...more
As described in our previous alert, the American Rescue Plan Act of 2021 (the ARPA), provides a full subsidy for COBRA premiums for certain qualified beneficiaries entitled to COBRA continuation coverage from April 1, 2021,...more
The American Rescue Plan Act (“ARPA”), signed into law on March 11, 2021, obligates employers to pay COBRA insurance premiums for individuals who suffer job loss. Under the plan, employers receive the subsidy, which they pass...more
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
New ARPA/COBRA Subsidy - The federal American Rescue Plan Act of 2021 (ARPA) provides for a 100% subsidy of COBRA premiums for six months from April 1, 2021 through September 30, 2021, for individuals (and their covered...more
The recently signed American Rescue Plan Act (ARPA) will have a major impact during the next six months on employers' obligations and considerations in administering COBRA health insurance benefits. Subtitle F of ARPA –...more