Insights on benefits counseling and litigation issues impacting employers nationwide
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…
On July 9, 2021, the PBGC issued its interim final rule (the “Rule”) on the process for eligible troubled Multiemployer Pension Plans (“MEPPs”) to apply for and obtain Special Financial Assistance (“SFA”) under the American Rescue Plan Act of 2021 (“ARPA”). The Rule was posted on PBGC’s website and became effective as guidance on July…
In the clamor that surrounded the current administration’s adoption of the American Rescue Act of 2021 (ARPA), quietly tucked in as Subtitle H is the Butch Lewis Emergency Pension Plan Relief Act of 2021 (Butch Lewis). Butch Lewis has been unsuccessfully bouncing around Congress since 2019. While Butch Lewis is long on rhetoric, at this…
The Emergency Pension Plan Relief Act of 2021 (EPPRA), enacted as part of the American Rescue Plan Act of 2021 (ARPA), contained unprecedented financial relief for the most troubled multiemployer pension plans (MEPPs). The MEPPs community is eagerly awaiting guidance from the Pension Benefit Guaranty Corporation (PBGC) on the requirements for MEPPs to apply for …
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…
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…
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…
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.…
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…
