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
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…
New Model COBRA Notices and Emergency Extensions to COBRA Deadlines Require Employers to Take Action
By Brian M. Johnston & Keith A. Dropkin on
Posted in COBRA, coronavirus, covid-19, DOL, EBSA, Employee Health & Welfare Plans, ERISA, IRS, Plan Administrator, qualifying event
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…
Employee Benefits Issues to Consider Before Deciding to Furlough or Terminate Employees During the COVID-19 Pandemic
With the combination of our nation’s response to COVID-19 and the resultant economic downturn, employers of all sizes face the moral and financial dilemma of evaluating employee headcounts while businesses are grappling with the reality of the current situation. Many employers are considering furloughs, or other types of approved leaves of absences, to reduce immediate…
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.…
DOL Proposes Changes to Model Notices and Procedures
The Department of Labor (DOL) has published proposed regulations containing amendments to the COBRA notice provisions. The amendments are intended to align the model general and election notices with the Affordable Care Act provisions already in effect and to ensure that the DOL will have flexibility to modify the model notices going forward.
The proposed…
The DOL Has Started Auditing Group Health Plans for PPACA, as well as GINA and Wellness Program Compliance
The DOL has begun to audit PPACA compliance, is your plan ready?
Continue Reading The DOL Has Started Auditing Group Health Plans for PPACA, as well as GINA and Wellness Program Compliance