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Benefit Plan Sponsors Department of Labor (DOL) Consolidated Omnibus Budget Reconciliation Act

Holland & Hart - The Benefits Dial

You Say It’s Your Birthday?! Well, It’s ERISA’s Birthday, Too!

Employee benefits law is mostly drawn from two federal sources—the Internal Revenue Code and ERISA. Just what is “ERISA,” though? Its official reference is the “Employee Retirement Income Security Act of 1974.” That means the...more

Bass, Berry & Sims PLC

2023 ERISA Welfare Plan Automatic Participant Disclosures Checklist

Bass, Berry & Sims PLC on

ERISA requires plan sponsors to distribute SPDs to inform participants of their benefits, rights, and obligations under the plan and describe how the plan operates. Department of Labor (DOL) regulations (available here)...more

Woods Rogers

Does the Fun Ever Stop? COVID-19 Tolling Ends for COBRA Deadlines

Woods Rogers on

On April 10, 2023, President Biden signed legislation to end the COVID-19 national emergency effective immediately, including ending the requirement to extend COBRA deadlines due to the COVID-19 pandemic. Plan administrators...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Deadline Tolling

McDermott Will & Emery on

The Biden administration previously announced its intent to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information). On April...more

Davis Wright Tremaine LLP

Agencies Release FAQs Confirming Impact of End of the COVID-19 Emergency Declarations on Employee Benefit Plans

Employers should prepare now for impacts to their employee benefit plans when the COVID-19 Outbreak Period expires. On March 29, 2023, in anticipation of the ends of both the National Emergency and Public Health Emergency,...more

Alston & Bird

Breaking Up Is Hard to Do: The End of the COVID Mandates and Outbreak Period Extensions

Alston & Bird on

The National Emergency brought about by the COVID-19 pandemic may be at an end, but there are still administrative details to sort out. Our Employee Benefits & Executive Compensation Group provides in-depth analysis for how...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

No Change in DOL/Treasury Guidance for Employer Health Plans Issued Before Declared End of COVID-19 National Emergency

What does the April 10, 2023, early end of the COVID-19 National Emergency declaration mean for employer health plans? Well, nothing, actually....more

Jackson Lewis P.C.

The National Emergency Ends…. But Wait, There’s More!

Jackson Lewis P.C. on

We previously wrote about President Biden’s announcement to end the COVID-19 Public Health Emergency (PHE) and National Emergency (NE) periods on May 11, 2023, and the practical ramifications for employer group health plan...more

Proskauer - Employee Benefits & Executive...

Update: Big Headline, Small Impact: Legislation Ends COVID-19 National Emergency

Important Update: Based on informal comments from the U.S. Department of Labor, it appears that the tolling of benefit plan deadlines will end on July 10, 2023, as described in our earlier blog on this subject,...more

Kaufman & Canoles

ESOPs & Employee Benefits Q1 2023 Client Update

Kaufman & Canoles on

Welcome to Spring! We hope the new season finds you ready for the upcoming benefits changes that 2023 has in store. ...more

Morgan Lewis

COVID-19 Public Health and National Emergencies to End May 11—or Earlier

Morgan Lewis on

With the COVID-19 public health emergency and the presidential declaration of national emergency intended to end on May 11 and the US government recently issuing guidance on unwinding these emergency declarations, this...more

McDermott Will & Emery

Preparing for the End of the COVID-19 Emergency: Tri-Agencies Issue FAQs to Assist Plans and Issuers

The Biden administration has announced its intention to end the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) on May 11, 2023 (read our series introduction for more information)....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Employers Prepare for Thawing ERISA Deadlines

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

Faegre Drinker Biddle & Reath LLP

Navigating Open Enrollment Notice Requirements

Fall open enrollment is upon us, and plan sponsors and administrators are preparing to provide their employees with the required notices related to their health and welfare plans. Notice and disclosure obligations for health...more

Woodruff Sawyer

Protecting Against the ERISA Litigation Surge

Woodruff Sawyer on

ERISA litigation has exploded in the past few years, particularly cases alleging excessive fees. Last year was the high-water mark for ERISA class actions with over 200 cases filed, an 80% increase from 2019. 2021 is on track...more

Snell & Wilmer

2021 End of Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

Snell & Wilmer on

We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Clarifies Application of Deadline Extensions to COBRA

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

Morgan Lewis - ML Benefits

American Rescue Plan Act of 2021 COBRA Subsidy Expiration Notice Is Due

The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy for up to six months, from April 1, 2021 through September 30, 2021, for Assistance Eligible Individuals (AEIs) as defined under the...more

BCLP

BCLP Benefits Newsletter: Summer 2021

BCLP on

Congress extended the availability of refundable tax credits for Eligible Employers who provide paid family leave or sick leave from April 1, 2021 to September 30, 2021 in connection with COVID-related illness. Under ARPA,...more

Jackson Lewis P.C.

The End Of A (Short) Era: ARPA COBRA Subsidies And The Remaining Action Item For Plan Sponsors

Jackson Lewis P.C. on

The American Rescue Plan Act of 2021 (“ARPA”) kept many practitioners busy this spring/summer. Under one of ARPA’s most impactful provisions, employees who were involuntarily terminated or had their hours reduced (and...more

Snell & Wilmer

Ironing Out the Wrinkles – IRS Answers 86 Questions About COBRA Relief Under the American Rescue Plan Act

Snell & Wilmer on

The American Rescue Plan Act (“ARPA”) has been the law of the land since March 11, 2021. Even so, many questions remained unanswered with respect to ARPA’s impact on group health plans. To resolve some of the lingering...more

Mintz - Employment Viewpoints

Department of Labor Issues Model COBRA Subsidy Notices and FAQs

The Department of Labor (“DOL”) has issued model notices regarding COBRA premium assistance (a/k/a COBRA subsidies). As we wrote about here, as part of the American Rescue Plan Act of 2021 (the “Act”), Congress sought to...more

Proskauer - Employee Benefits & Executive...

You’ve Sent the COBRA Special Extended Election Period Notices – What’s Next?

Due to tight timelines and an initial sprint to issue the special extended COBRA election period notices by the May 31st deadline, plan administrators may not have focused on the other COBRA-related notice requirements under...more

Proskauer - Employee Benefits & Executive...

ARP COBRA Subsidy Special Election Opportunity: Who Gets a Second Bite at the Apple, and How Do They Take It?

The American Rescue Plan (“ARP”) offers a special 60-day election period for certain individuals who previously declined or discontinued COBRA coverage (“Assistance Eligible Individuals” or “AEIs,” as defined in ARP). These...more

Smith Anderson

ARPA COBRA Subsidy's Impact on Employer Health Plans

Smith Anderson on

The American Rescue Plan Act of 2021 (ARPA) provides temporary COBRA continuation coverage premium assistance for certain eligible qualified beneficiaries. On April 7, 2021, the Department of Labor issued a FAQ and model...more

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