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COVID National Emergency Ends Early Impacting Health Plans

On April 10, 2023, President Biden signed a resolution ending the COVID-19 National Emergency. As we had previously reported, the National Emergency originally was scheduled to end on May 11, 2023 – at the same time as the...more

Preparing for the End of the COVID-19 Emergency Periods for Health Plans

President Biden recently announced his intention to end the COVID-19 National Emergency and Public Health Emergency effective May 11, 2023. As we previously discussed here, those emergency declarations had significant impacts...more

When Will the Pandemic End for Employer-Sponsored Health Plans?

While many in the U.S. have attempted to resume a sense of normalcy despite the ongoing COVID-19 pandemic, for employer-sponsored health plans, special “emergency” pandemic rules and extensions remain in effect. As previously...more

New IRS Guidance Offers Employers Direction regarding COBRA Subsidy Obligations

As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more

New DOL Guidance and Model Notices Assist Employers with Their New COBRA Subsidy Obligations

As we previously reported, the recently enacted American Rescue Plan Act of 2021 (ARPA) includes a six-month COBRA premium subsidy whereby the federal government subsidizes 100% of the COBRA premium during the period of April...more

Recent COBRA Developments Require Review of COBRA Policies and Practices

As summarized below, recent updates to Model COBRA Notices, extensions of deadlines as a result of COVID-19, and an uptick in class action lawsuits stemming from allegedly deficient COBRA Notices, will require a review of...more

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