News & Analysis as of

Consolidated Omnibus Budget Reconciliation Act Medicare Employee Benefits

Proskauer - Employee Benefits & Executive...

Interaction between COBRA and Medicare in C-Suite Executive Severance and Retirement Arrangements

Both companies and their C-suite executives should be mindful of the interactions between COBRA and Medicare and their implications when negotiating a severance or retirement arrangement. This is because Medicare enrollment...more

Foley & Lardner LLP

Thorny Laws That ICHRA Vendors Should Consider

Foley & Lardner LLP on

Individual Coverage Health Reimbursement Arrangements (ICHRAs) have continued to grow in popularity since their inception in 2019 (see our article here summarizing the 2019 rule establishing ICHRAs). While initially it seemed...more

McDermott Will & Emery

How Employers Should Prepare for the End of the Covid-19 National and Public Health Emergencies

McDermott Will & Emery on

On January 30, 2023, the Biden administration announced its intention to make final extensions of both the COVID-19 National Emergency (NE) and the COVID-19 Public Health Emergency (PHE) through May 11, 2023, at which point...more

Groom Law Group, Chartered

Top 5 Most Important Rules to Remember About the Interaction Between COBRA and Medicare

The COBRA rules and Medicare rules are complex on their own. Navigating the interaction between the rules is even more complex and can lead to an inadvertent compliance issue. Given today’s highly litigious COBRA world and...more

Verrill

Employee Benefits & Executive Compensation 2021 Summer Client Advisory

Verrill on

This Client Advisory summarizes developments in the law governing employee benefit plans prompted by the COVID-19 pandemic. We explain what these developments mean for plan sponsors and highlight the need to adopt plan...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

McDermott Will & Emery

American Rescue Plan Act of 2021: Key Healthcare Provisions

On March 10, 2021, US Congress finalized and passed the American Rescue Plan of 2021 (ARPA), the latest COVID-19 relief package that largely tracks President Joe Biden’s initial $1.9 trillion proposal. The ARPA extends...more

Proskauer - Employee Benefits & Executive...

Some Family Members May Not Be Eligible for the ARPA COBRA Premium Subsidy

The American Rescue Plan Act of 2021 (“ARPA”) includes a 100% COBRA premium subsidy for “assistance eligible individuals,” for periods of coverage occurring between April 1, 2021 and September 30, 2021, as described in...more

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

New COVID-19 Relief Law Includes Full COBRA Premium Subsidy

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

Proskauer - Employee Benefits & Executive...

COVID-19 Stimulus Bill Includes Six Months of Free COBRA Health Coverage

The American Rescue Plan Act of 2021 (“ARPA”), which was just passed by Congress and will be sent to President Biden for signature, includes an opportunity for free COBRA coverage for a six-month period from April through...more

Perkins Coie

US Department of Labor Issues Updated COBRA Model Notices and Related FAQS

Perkins Coie on

The U.S. Department of Labor (DOL) issued revised model general and election notices on Friday, May 1, 2020. The notices can be used by plan administrators to address the notification requirements imposed by the Consolidated...more

McDermott Will & Emery

Department of Labor Updates COBRA FAQs and Model Notices

On May 1, 2020, the Department of Labor (DOL) issued updated Frequently Asked Questions and revised model notices under the Consolidated Omnibus Budget Reconciliation Act (COBRA). COBRA is a federal law that permits...more

Littler

DOL Releases New Model COBRA Notices Amid Continued Wave of Litigation

Littler on

On May 1, 2020, the Department of Labor released new versions of its model COBRA notices, adding a new action item for employers facing a contracting workforce and a growing wave of participant litigation....more

Kilpatrick

DOL Issues New COBRA Notices - Litigation Trend to Remain Unphased

Kilpatrick on

The Department of Labor (“DOL”) posted new model notices on its website which employers may use to satisfy notice obligations under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), along with a short...more

Holland & Hart - The Benefits Dial

I am not throwing away my shot: Retiree coverage as an alternative to COBRA

The COBRA requirements with respect to termination of active employee group health coverage and the coincident availability of retiree medical coverage are complex and not intuitive.  In short, if retiree coverage will not...more

Burr & Forman

What the HRA is going on with HRAs?

Burr & Forman on

On June 13, the Departments of Labor, Treasury and Health and Human Services jointly released final regulations dealing with health reimbursement accounts (“HRAs”). These regulations fulfill the Trump administration’s...more

Mintz - Employment Viewpoints

Agencies Issue Final Regulations Expanding Access to Health Reimbursement Arrangements

On June 13, 2019, the Department of Health and Human Services (HHS), the Department of Labor (DOL), the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) (collectively, the “Departments”)...more

McDermott Will & Emery

Medicare Part D Creditable Coverage Notices due before October 15, 2018

McDermott Will & Emery on

The Medicare Modernization Act of 2003 requires employers who offer prescription drug coverage to provide an annual notice to all Medicare Part D eligible individuals who are participants in, or eligible for, the employer’s...more

Winstead PC

U.S. Supreme Court Ruling: Defense of Marriage Act ("DOMA")

Winstead PC on

While the U.S. Supreme Court(the “Court”) ruled section 3 of the Defense of Marriage Act (“DOMA”) unconstitutional, that does not mean that the changes for human resources departments and employee benefits plans can be...more

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