When an employee is on an extended leave of absence, there is often confusion regarding whether and to what extent the employer must continue to provide coverage to the employee under the employer-provided health plan. To determine whether coverage is required, the employer should consider the terms of the plan, COBRA requirements, and whether the
The National Emergency Ends…. But Wait, There’s More!
We previously wrote about President Biden’s announcement to end the COVID-19 Public Health Emergency (PHE) and National Emergency (NE) periods on May 11, 2023, and the practical ramifications for employer group health plan sponsors as they administer COBRA, special enrollment, and other related deadlines tied to the end of the NE. As discussed, this action
National Employee Benefits Day is April 6th!
With another National Employee Benefits Day upon us, it is a good reminder for all involved in the world of Employee Benefits to pause (take three deep breaths) and use it as an opportunity to look back at where we’ve been over the last year and where we are going. While the challenges are many
What the End of the COVID-19 Pandemic Means for Employee Benefit Plan Deadlines and Coverage
President Biden announced that the COVID-19 Public Health Emergency (PHE) and the National Emergency declared by President Trump in 2020 will end on May 11, 2023. The PHE relief issued in response to the pandemic affected group health plan coverage requirements related to COVID-19 prevention and treatment. The National Emergency relief suspended deadlines that
A Brief Status Report On COBRA
The normal difficulties that employers have adhering to the technical requirements of COBRA have been exacerbated during the past two years as COBRA rules were changed to recognize the complications accompanying the COVID-19 pandemic. This added complexity is particularly worrisome as an employer’s simple oversight in administering COBRA can result in ERISA penalties, an excise
The End of a (Short) Era: ARPA COBRA Subsidies and the Remaining Action Item for Plan Sponsors
The American Rescue Plan Act of 2021 (“ARPA”) kept many practitioners busy this spring/summer, as may be evident by our discussions here, here, here, and here.
Under one of ARPA’s most impactful provisions, employees who were involuntarily terminated or had their hours reduced (and who met certain other criteria) became eligible
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
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
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
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.