Archives: COBRA

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IRS Provides Clarity on ARPA COBRA Subsidy Impact on State “Mini-COBRA” Plans

In our most recent summary of IRS Notice 2021-31, we noted the Internal Revenue Service provided much-needed clarity to looming compliance challenges as employers, insurers, and others race to implement the applicable COBRA premium subsidy provisions of the American Rescue Plan Act of 2021 (ARPA).  While there are many other important clarifications made by the … Continue Reading

IRS Answers to Your American Rescue Plan Act COBRA Subsidy Questions

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 … Continue Reading

Model ARPA COBRA Notices Have Arrived!

On April 7, 2021, the U.S. Department of Labor (DOL) issued eagerly anticipated guidance on administering COBRA subsidies under the American Rescue Plan Act of 2021 (ARPA). The guidance includes Frequently Asked Questions (FAQs) and various Model Notices and election forms implementing the COBRA Premium Assistance provisions under ARPA, while also announcing the launch of … Continue Reading

Happy National Employee Benefits Day, April 6, 2021!

You didn’t know it was a thing?  Or maybe, like most, you just lost track of what day it is?  Or maybe it ranks somewhere behind New Beer’s Eve (the day before the end of prohibition) and National Tartan Day, both of which are most certainly things and also fall on April 6th. If there … Continue Reading

American Rescue Plan Act of 2021: COBRA Subsidy, Pension Funding, and Other Employee Benefit Changes

The American Rescue Plan Act of 2021 (ARPA) is the latest federal COVID-19 relief bill, which the President signed into law on Thursday, March 11, 2021. ARPA includes new COBRA continuation coverage election, notice, and subsidy requirements; pension plan funding relief; and some cost-saving benefit opportunities employees may be able to leverage.  Some of these … Continue Reading

COVID-19 Deadline Extensions—No More Time Outs but No Single Deadline Either!!

We recently provided an update on the looming end date for COBRA and other deadline extensions and the uncertainty that continues to add to the administrative burdens without more clarity from the DOL and IRS.  Message received, apparently. On behalf of the IRS, the DOL has now released Disaster Relief Notice 2021-01 that attempts to … Continue Reading

COVID-19 Deadline Extensions—Still Relevant to Plan Sponsors?

In May of 2020, the Department of Labor (DOL) and Internal Revenue Service (IRS) released joint-agency guidance that extended several important deadlines for employees, including COBRA election and payment deadlines, HIPAA Special Enrollment deadlines, and claims submission and appeal deadlines.  Under the guidance, plan administrators were required to extend the deadlines that would otherwise apply … Continue Reading

COBRA Compliance Through a COVID-19 Lens

Over the last few weeks, we have seen significant changes affecting COBRA compliance. Employers should contact their COBRA administrators to discuss the best practices in light of these developments, which include the Department of Labor’s publication of new model COBRA notices and COVID-19 notice and premium payment extensions.  We have a helpful article that discusses … Continue Reading

New Model COBRA Notices and Emergency Extensions to COBRA Deadlines Require Employers to Take Action

The Department of Labor (DOL) and other federal regulators released updates and clarifications related to employee benefits, including updates to model COBRA notices and an extension of certain statutory deadlines intended to minimize the possibility of participants and beneficiaries losing benefits during the COVID-19 pandemic. This article highlights the DOL’s recent changes and updates relating … Continue Reading

COBRA Notice Litigation Resulting in Big Dollar Claims

Can you imagine something as simple as a COBRA Notice missing a few technical requirements resulting in an employer needing to pay a 6 or 7-digit damages award?  That is happening in Florida.  Employers in and out of Florida should pay attention to this news, as what doesn’t start in California often starts in Florida. … Continue Reading
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