As employers plan for the impact of the anticipated May 11, 2023, end of the two federal COVID-19 emergency orders, they have some important new clarity on test and vaccine coverage and on how to unwind COVID-19–era extended...more
4/4/2023
/ Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Health and Human Services (HHS) ,
Health Savings Accounts ,
New Guidance ,
Public Health Emergency ,
Secretary of HHS ,
Vaccinations ,
Virus Testing
With the pandemic winding down, deadlines for employee benefit plans governed by the Employee Retirement Income Security Act (ERISA) will be resuming. Two different emergencies affect employer-sponsored group health plans:...more
2/8/2023
/ Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Employer Group Health Plans ,
Filing Deadlines ,
Health Insurance Portability and Accountability Act (HIPAA) ,
IRS ,
Joint Statements ,
Public Health Emergency ,
Relief Measures ,
Time Extensions
The Internal Revenue Service (IRS) recently issued some much-needed guidance surrounding the application of deadline extensions that the IRS and the U.S. Department of Labor (DOL) previously issued for initial elections under...more
The American Rescue Plan Act of 2021 (ARPA) implemented a 100 percent COBRA subsidy for certain qualified beneficiaries beginning on April 1, 2021, and ending September 30, 2021. On May 18, 2021, more than a month into the...more
The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it...more
4/28/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
New Guidance ,
Notice Requirements ,
Premium Subsidies ,
Relief Measures ,
Tax Credits
Less than a month after the American Rescue Plan Act of 2021 (ARPA) was signed into law, new U.S. Department of Labor (DOL) guidance and model forms are clearing up a number of employer concerns about the 100 percent COBRA...more
4/12/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
EBSA ,
Employee Benefits ,
Employer Group Health Plans ,
Health Insurance ,
IRS ,
New Guidance ,
Premium Subsidies ,
Premiums ,
Relief Measures ,
Tax Credits
The U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) published EBSA Disaster Relief Notice 2021-01 in the nick of time on February 26, 2021. EBSA Disaster Relief Notice 2021-01 was released...more
4/1/2021
/ Benefit Plan Sponsors ,
Biden Administration ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
EBSA ,
Employee Benefits ,
Executive Orders ,
Health Insurance ,
Health Insurance Portability and Accountability Act (HIPAA) ,
New Guidance ,
Notice Requirements ,
Relief Measures ,
Time Extensions
The American Rescue Plan Act of 2021 (ARPA), which became law on March 11, 2021, provides a 100 percent subsidy of premiums under the Consolidated Omnibus Budget Reconciliation Act (COBRA) beginning on April 1, 2021, through...more
3/18/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
Biden Administration ,
COBRA ,
Coronavirus/COVID-19 ,
Employee Benefits ,
Employer Group Health Plans ,
Families First Coronavirus Response Act (FFCRA) ,
Health Insurance ,
Medicare ,
Notice Requirements ,
Popular ,
Premium Subsidies ,
Relief Measures ,
Tax Credits
The Consolidated Appropriations Act, 2021 (CAA) contained temporary relief measures aimed at addressing unused contributions to health flexible spending accounts (FSA) and dependent care assistance programs (DCAP).
On...more
3/11/2021
/ Benefit Plan Sponsors ,
Cafeteria Plans ,
CARES Act ,
Carry-Over Basis ,
COBRA ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Deductibles ,
Dependent Care Assistance Program (DCAP) ,
Employee Benefits ,
Flexible Spending Accounts ,
Grace Period ,
Health Savings Accounts ,
IRS ,
Relief Measures
Employers are facing uncertainty as to the expiration of the COVID-19 relief the U.S. Department of Labor (DOL) and Internal Revenue Service (IRS) issued in a joint guidance on May 4, 2020. The joint guidance requires...more
Starting in 2020, employers will be able to offer health reimbursement arrangements (HRAs) that work in conjunction with individual coverage or Medicare without running afoul of the Affordable Care Act’s (ACA) market reform...more