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
Employee Health & Welfare Plans
Washington Steps Up Insurance Protections for Gender Affirming Treatments
As some states make headlines for so-called “anti-trans” laws, the Washington state legislature rejected a bill designed to limit youth participation in sports based on their gender as assigned on a birth certificate and passed the new Gender Affirming Treatment Act. This Act prohibits health insurers from denying or limiting coverage for gender affirming treatment…
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…
Remote Employees: The Geographic Tax and Benefits Challenges
As the COVID-19 vaccine has become readily available, and many employers contemplate employees returning to the office to work, both employers and employees have accelerated demands for new and permanent remote work location arrangements for a variety of jobs. Employers across the country are revisiting their business strategies, employment policies, and related legal and tax…
Mental Health Parity Compliance Returns to Forefront for Group Health Plan Sponsors
The Consolidated Appropriations Act, 2021 (CAA) amended the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to include substantial new compliance requirements. The Department of Labor (DOL), Health and Human Services, and the Treasury (collectively, the Departments) have released much-anticipated guidance for group health plans necessitating action from plan sponsors. More…
COVID-19 Vaccination: Setting Up An On-site Program
The Biden administration reportedly has called for all people at least 18 to be eligible for the COVID-19 vaccine by April 19, 2021, two weeks earlier than its prior goal of May 1, and less than a week away. Most states have already done so. Without the barriers created by state-by-state priority rules, the…
Lawmakers Seek Clarity on EEOC Regulations Concerning Incentives for COVID-19 Vaccinations
Providing incentives for employees to get the COVID-19 vaccine continues to be on the minds of organizations as vaccinations pick up speed. However, concerns about privacy and the shifting positions on wellness program regulation has left many employers wary about implementing more robust incentives. According to Bloomberg, two GOP members of Congress are urging…
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.…
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…
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…