News & Analysis as of October 6, 2024

Health Insurance

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Read guidance, analysis, and updates on the myriad issues arising from the global response to the COVID-19 pandemic. Updated hourly every day, the insights published here are written by leading lawyers and law firms helping to make sense of insurance, employment, tax, securities, M&A, risk management, and every other consideration touched by this crisis. Follow the channel for a daily email brief of the latest and best updates. less -

Developments in Association Law 2022 – 2024

Pillsbury Winthrop Shaw Pittman LLP on 9/16/2024

The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more

HSA Holders Lament the End of the Era of Free Invasive Nasal Swabs: IRS to Remove COVID Exemption for HDHPs

Seyfarth Shaw LLP on 7/13/2023

Seyfarth Synopsis: In light of the end of the COVID-19 National Emergency and Public Health Emergency, the Internal Revenue Service (“IRS”) has announced the end of prior COVID-19-related special rules for health plan...more

IRS Clarifies HDHP Coverage of COVID-19 Testing, Treatment Before Deductible

Holland & Knight LLP on 7/10/2023

The IRS recently issued Notice 2023-37 (Notice) relating to pre-deductible coverage of COVID-19 testing and treatment under high-deductible health plans (HDHPs). Specifically, the Notice establishes a 2024 expiration date for...more

COVID-19 Coverage Without a Deductible Ends After 2024

Ballard Spahr LLP on 6/30/2023

The Internal Revenue Service (IRS) has issued new guidance, Notice 2023-37, which states that for plan years ending after December 31, 2024, HSA-compatible high-deductible health plans (HDHPs) will no longer be permitted to...more

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

Woods Rogers on 5/19/2023

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

Whiplash: The Orderly and Disorderly End to the COVID-19 Declarations

Ballard Spahr LLP on 4/14/2023

Summary - Sponsors of employee benefit plans face heightened plan design and administrative challenges in the wake of President Biden’s surprise termination of the COVID-19 national emergency. This unexpected development,...more

Tolling No More: Preparing for the End of COVID-19 Emergency Declarations

Bass, Berry & Sims PLC on 3/8/2023

On January 30, President Biden announced his intention to end the COVID-19 National Emergency (NE) and Public Health Emergency (PHE) effective May 11, 2023. Both emergency declarations resulted in various forms of relief for...more

Planning for 2022: Year-End Deadlines and Considerations for Employee Retirement, Health and Welfare Plans

Husch Blackwell LLP on 11/8/2021

With the end of the year fast approaching, employers should be aware of several important deadlines and considerations related to retirement and health and welfare plans. With the onslaught of recent COVID-19-related...more

COBRA Election and Payment Periods: Does One Year of “Tolling” Really Mean One Year?

Proskauer - Employee Benefits & Executive... on 10/8/2021

Remember the DOL/Treasury relief that tolled the COBRA election and payment deadlines for up to one year due to the COVID-19 pandemic (referred to below as “Tolling Relief”)? If you have been wondering whether, under that...more

IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA

Stinson - Benefits Notes Blog on 6/1/2021

On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provided by the...more

IRS Issues Guidance on the American Rescue Plan Act COBRA Subsidy

Littler on 5/27/2021

On March 11, 2021, President Biden signed into law the American Rescue Plan Act (ARPA) that contains a new, temporary COBRA subsidy. The ARPA COBRA subsidy requires employers to cover 100% of an employee’s cost of continuing...more

New IRS Guidance Offers Employers Direction regarding COBRA Subsidy Obligations

Laner Muchin, Ltd. on 5/26/2021

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

IRS Releases Guidance on COBRA Premium Subsidy

Locke Lord LLP on 5/26/2021

On May 18, 2021, the Internal Revenue Service issued Notice 2021-31 ‎(the “Notice”) ‎providing much anticipated guidance on implementing the COBRA subsidy provisions under the American Rescue Plan Act (the “Act”). ...more

IRS Guidance on ARPA COBRA Subsidies: 86 Q&As and Counting

Epstein Becker & Green on 5/25/2021

As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”) into law on March 11, 2021, which, among other things, mandates that employers provide 100 percent COBRA premium subsidies to eligible...more

IRS Issues Guidance Regarding American Rescue Plan Act COBRA Subsidy

Morgan Lewis on 5/21/2021

The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more

Good News and Bad News: The IRS Issues 86 Q&A’s on the ARP COBRA Subsidy

McNees Wallace & Nurick LLC on 5/21/2021

On May 18, 2021, the IRS issued the long- awaited guidance on the COBRA subsidy and premium assistance credit available under the American Rescue Plan Act of 2021 through eighty-six questions and answers....more

IRS Clarifies Key Provisions of the COBRA Subsidy

Robinson & Cole LLP on 5/20/2021

As anticipated, the Internal Revenue Service (IRS) issued Notice 2021-31 (the Notice) yesterday, providing important guidance to employers and plan administrators regarding their COBRA subsidy-related obligations under the...more

New COBRA Coverage Obligations for Employers

Lippes Mathias LLP on 4/28/2021

Notice To Employers And Group Health Plans – New COBRA Continuation Coverage Obligations And Premium Subsidies Under The American Rescue Plan Act Of 2021....more

U.S. Labor Department Answers Some - But Not All - Key Questions About New COBRA Subsidies

Parker Poe Adams & Bernstein LLP on 4/16/2021

As previously reported in EmployNews, the American Rescue Plan Act provides “assistance eligible individuals” with the option to receive fully-subsidized COBRA coverage from April 1, 2021 through September 30, 2021....more

COBRA Subsidy: What We Know Now After Initial DOL Guidance

Ogletree, Deakins, Nash, Smoak & Stewart,... on 4/12/2021

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

COBRA Premium Subsidy Under the American Rescue Plan Act

Holland & Knight LLP on 3/31/2021

The recently signed American Rescue Plan Act (ARPA) will have a major impact during the next six months on employers' obligations and considerations in administering COBRA health insurance benefits. Subtitle F of ARPA –...more

Overview Of Employee Benefit Provisions In The Consolidated Appropriations Act

Fisher Phillips on 3/5/2021

The Consolidated Appropriation Act of 2021 was signed into law on December 27, 2020 and is an impressive 5,593 pages. According to the Senate Historical Office, the Act is the longest bill ever passed by Congress. Buried...more

Outbreak Period to Be Applied on a One-Year Rolling Basis

Stoel Rives LLP on 3/4/2021

In this legal update, our employee benefits attorneys cover three recent health and welfare plan developments....more

Coronavirus: The Hill and the Headlines, February 2021 # 11

Hogan Lovells on 2/16/2021

In Washington: President Biden will join leaders of the Group of Seven (G-7) nations this Friday for a virtual summit focused on the global response to COVID-19, the White House said Sunday. Other discussions at the summit...more

Weekly IRS Roundup November 23 – November 27, 2020

McDermott Will & Emery on 12/1/2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020... November 23, 2020: The IRS released TD 9935, providing...more

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