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May 31, 2021 Deadline Approaching for ARPA’s COBRA Subsidy Election Notices

As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”), a $1.9 trillion COVID-19 relief package, into law on March 11, 2021, which, among other things, mandates that employers provide 100...more

New COBRA Notices & Extended Deadlines May Create Traps for the Unwary: Benefits Guidance in the Time of COVID-19

The economic downturn caused by COVID-19 pandemic has resulted in an unprecedented number of layoffs, furloughs, and reduced hours. Under the Consolidated Omnibus Budget Reconciliation Act (“COBRA”)...more

IRS Memo Concludes No There Is Statute of Limitations for ACA Employer Mandate Penalties Under Internal Revenue Code § 4980H

The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more

Back to Business: Five Developments Impacting Health Care Employers - Take 5 Newsletter August 2019

As summer winds down, the challenges impacting health care employers in 2019 continue to heat up. These challenges include ongoing developments regarding marijuana legalization, employee resistance to vaccination mandates,...more

The Proposed Expansion of Health Reimbursement Arrangements: Is This a Game Changer for Employers?

On October 22, 2018, in perhaps the most significant guidance resulting from President Trump’s 2017 Executive Order 13813, “Promoting Healthcare Choice and Competition Across the United States” (“2017 Executive Order”), the...more

New Jersey’s Surprise Medical Bill Law: Part 2: Comparison to New York’s and California’s “Surprise Bill” Laws

New Jersey’s Out-of-Network Consumer Protection, Transparency, Cost Containment and Accountability Act (“NJ Law”) creates a statutory framework that attempts to protect consumers from medical bills for out-of-network services...more

New Jersey’s Surprise Medical Bill Law: Part 1: Regulatory Issuances by New Jersey Agencies

Earlier this year, New Jersey Governor Phil Murphy signed into law the Out-of-Network Consumer Protection, Transparency, Cost Containment and Accountability Act (“Law”), creating a statutory framework attempting to protect...more

Self-Funded ERISA Health Plans and New Jersey’s “Surprise” Out-of-Network Medical Bill Law: Are You In or Out? It’s Time to Decide

On June 1, 2018, New Jersey Governor Phil Murphy signed the Out-of-Network Consumer Protection, Transparency, Cost Containment and Accountability Act (“Surprise Medical Bill Law”), which is intended to protect against...more

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