In much-anticipated guidance, the Internal Revenue Service has offered its insight on the implementation of the COBRA temporary premium subsidy provisions of the American Rescue Plan Act of 2021 (ARPA) in Notice 2021-31.

Spanning more than 40 pages, the IRS-answered frequently asked questions (FAQs) finally resolve many issues relating to temporary premium assistance for COBRA continuation coverage left unanswered in the Department of Labor’s publication of model notices, election forms, and FAQs.

The practical implications of the guidance for employers are many. Significantly, employers must take action prior to May 31, 2021, to ensure compliance with some of the requirements under ARPA and related agency guidance.  More

Tags: American Rescue Plan Act 2021, ARPA, COBRA, COBRA subsidies
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Photo of Joy M. Napier-Joyce Joy M. Napier-Joyce

Joy M. Napier-Joyce is a principal in the Baltimore, Maryland, office of Jackson Lewis P.C.

Joy counsels clients in a broad range of benefit matters, including general compliance and administration of qualified retirement plans under ERISA and the Internal Revenue Code. She also…

Joy M. Napier-Joyce is a principal in the Baltimore, Maryland, office of Jackson Lewis P.C.

Joy counsels clients in a broad range of benefit matters, including general compliance and administration of qualified retirement plans under ERISA and the Internal Revenue Code. She also assists clients with welfare plan issues involving cafeteria plans, health plans, flexible spending accounts, group insurance products, COBRA and HIPAA. Joy has a particular focus on assisting employers with the various compliance requirements associated with federal health care reform and has been a frequent speaker on the topic. Her practice also includes advice on non-qualified deferred compensation arrangements and other executive compensation matters, including issues related to compliance with Section 409A of the Internal Revenue Code.

As part of her practice, Joy frequently assists clients with a variety of benefits issues arising in corporate mergers and acquisitions and restructurings of all forms. This includes analyzing benefits risks for buyers, handling plan corrections and terminations, strategizing and implementing benefits arrangements post-closing and advising on controlled group considerations.

Joy represents clients in dealings with the Internal Revenue Service and the Department of Labor, including EPCRS applications, private letter rulings, determination letter applications and plan audits. She negotiates with outside benefits providers, including prototype plan sponsors, third party administrators, insurers, actuaries and auditors. She also counsels both public and private clients on a wide array of tax and securities law issues in relation to equity-based arrangements.

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Photo of Suzanne G. Odom Suzanne G. Odom

Suzanne G. Odom is a principal in the Greenville, South Carolina, office of Jackson Lewis P.C. She focuses her practice on ERISA plans, employee benefits, and executive compensation matters.

Sue has worked extensively with all types of employer-sponsored retirement and welfare benefit plans…

Suzanne G. Odom is a principal in the Greenville, South Carolina, office of Jackson Lewis P.C. She focuses her practice on ERISA plans, employee benefits, and executive compensation matters.

Sue has worked extensively with all types of employer-sponsored retirement and welfare benefit plans, including pension, profit sharing, 401(k), 403(b), and 457(b) plans, ESOPs, and health, accident, disability, Section 125, flexible spending, and other welfare plans. Her clients include large and small for-profit companies across all industry sectors, non-profit corporations, and governmental entities.

As a result of Sue’s vast number of submissions and compliance matters, she has developed a close and professional working relationship with both the IRS and Department of Labor Representatives. Her practice is centered on providing her clients with solid and proactive fiduciary and business advice that assists them in avoiding the time and expense of employee benefits litigation.

Sue prides herself on her ability to think outside the box and work with clients to deliver the best business solutions possible.

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Photo of Melissa Ostrower Melissa Ostrower

Melissa Ostrower is a principal in the New York City, New York, office of Jackson Lewis P.C. and co-leader of the firm’s Employee Benefits practice group. She counsels clients in a broad range of employee benefit matters, including general compliance and administration of…

Melissa Ostrower is a principal in the New York City, New York, office of Jackson Lewis P.C. and co-leader of the firm’s Employee Benefits practice group. She counsels clients in a broad range of employee benefit matters, including general compliance and administration of qualified retirement plans and nonqualified retirement plans.

Melissa assists clients with welfare plan issues involving cafeteria plans, health plans, flexible spending accounts, COBRA and the Affordable Care Act. She regularly speaks on all benefits issues including federal health care reform, fiduciary compliance and executive compensation.

Melissa regularly advises on executive compensation matters, including issues related to compliance with Section 409A, 162(m) and 280G of the Internal Revenue Code.

Melissa represents clients in connection with Internal Revenue Service and the Department of Labor audits and information requests. She also regularly assists clients in fixing plan operational and document errors. Melissa negotiates with benefits providers, volume submitter and prototype vendors, TPAs, insurers and auditors.

Melissa also advises clients in connection with phantom and equity based compensation arrangements.

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