Summary The almost three-year-old COVID-19 national emergency and public health emergency declarations (Declarations) are slated to expire May 11, 2023. The Upshot The Bottom Line Plan sponsors should use the coming months to work with their advisors and administrators to ensure that their plan design, documents, and communications are appropriately reviewed and, if necessary, revised [&hellip… Continue Reading »
The IRS (with the concurrence of the DOL and HHS) has issued new guidance explaining how the extension of the deadline for paying COBRA premiums will be applied. The extension of deadlines for individuals to elect COBRA and pay for COBRA premiums on account of the COVID-19 pandemic remains in effect. These rules operate by [&hellip… Continue Reading »
The subsidy for COBRA coverage under the American Rescue Plan Act comes to an end on September 30, 2021. There is no indication at this time that the subsidy will be extended. That means that, beginning October 1, plan and COBRA administrators may start collecting premium payments from individuals who qualified for COBRA because of [&hellip… Continue Reading »
The IRS issued a new notice that provides guidance on a few issues that were not fully addressed in its earlier notice on the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium subsidy requirements set forth in the American Rescue Plan Act (ARPA). ARPA generally requires the cost of coverage under COBRA between April 1, 2021, and September 30, 2021, to [&hellip… Continue Reading »
This is a reminder that a COBRA notice deadline is approaching. It applies to employers that are subject to the federal COBRA rules. The American Rescue Plan Act (ARPA) requires employers that are subject to the federal COBRA rules to provide notice to those who do not currently have COBRA continuation coverage, but who are [&hellip… Continue Reading »
Summary The IRS issued guidance on a wide range of questions pertaining to the subsidies that employers are required to offer to COBRA qualified beneficiaries under the American Rescue Plan Act. The Upshot The guidance follows up on prior U.S. Department of Labor guidance, is generally consistent with prior IRS guidance, and includes an extensive [&hellip… Continue Reading »
The U.S. Department of Labor issued guidance on April 7 about the new COBRA subsidy rules under the American Rescue Plan (ARP). However, the DOL left some significant questions unanswered. More guidance on the COBRA provisions in ARP are expected. But until then, we address the most common questions below in an effort to provide [&hellip… Continue Reading »
The United States Department of Labor has issued much anticipated guidance and model forms under the COBRA subsidy rules introduced by the American Rescue Plan (ARP). The FAQ guidance and forms clarify some issues that employers have raised about the COBRA subsidy provisions of the ARP, but leave a number of the most significant questions unanswered. Clarifications and confirmations [&hellip… Continue Reading »
The American Rescue Plan (ARP) will have significant and immediate impacts on employee benefit plans, employers, and other plan sponsors and plan administrators. President Biden signed the ARP stimulus bill today. We highlight the most significant employee benefits and executive compensation changes under the ARP below. COBRA Provisions Section 9501 of the ARP requires employers [&hellip… Continue Reading »
The U.S. Department of Labor issued a notice that addresses how the extension announced last year for certain employee benefit deadlines will apply now that the commencement date for the extension has passed its one-year anniversary. Last spring, the DOL and IRS issued two notices that extended various deadlines for employee benefit plans and their [&hellip… Continue Reading »
The IRS issued a notice that addresses many of the questions employers have raised about flexible spending accounts (FSAs) in view of the new rules set forth in the Consolidated Appropriations Act (CAA). The CAA provides temporary relief for concerns raised by the COVID-19 pandemic by allowing: 1. temporary expansions of the opportunity to carry [&hellip… Continue Reading »
Group health plan sponsors and administrators may soon need to introduce changes to their offer of continued coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). The House Education and Labor Committee has proposed temporary COBRA subsidies and other modifications as part of the current COVID-19 stimulus package that is working its way [&hellip… Continue Reading »
