Littler Mendelson, P.C. • May 14, 2020
The IRS and DOL issued guidance on May 4, 2020 that adds a new level complexity to COBRA administration for employer-sponsored plans. In short, the relief suspends many key participant deadlines during the so-called “Outbreak Period.” The new rules define “Outbreak Period” to mean the period beginning March 1, 2020 and ending 60 days following the expiration of the National Emergency declaration related to COVID-19 (or at some other time in the future if the agencies decide to change the date).
Littler Mendelson, P.C. • May 05, 2020
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.
Jackson Lewis P.C. • May 04, 2020
The Department of Labor (DOL) and other federal regulators released updates and clarifications related to employee benefits, including updates to model COBRA notices and an extension of certain statutory deadlines intended to minimize the possibility of participants and beneficiaries losing benefits during the COVID-19 pandemic. This article highlights the DOL’s recent changes and updates relating to Consolidated Omnibus Budget Reconciliation Act (COBRA).
Jackson Lewis P.C. • March 04, 2020
Imagine something as simple as a COBRA notice that complies with law, but is not identical to the Department of Labor’s (DOL) model notice, leading to six- or seven-figure class action litigation settlements?
Jackson Lewis P.C. • September 23, 2019
Can you imagine something as simple as a COBRA Notice missing a few technical requirements resulting in an employer needing to pay a 6 or 7-digit damages award? That is happening in Florida. Employers in and out of Florida should pay attention to this news, as what doesn’t start in California often starts in Florida.
Ogletree Deakins • March 02, 2015
The Comprehensive Omnibus Budget Reconciliation Act of 1986 (COBRA) – part of the Employee Retirement Income Security Act (ERISA) – imposes an obligation on a healthcare coverage plan administrator to notify any employee covered by the administrator’s plan of that employee’s right to continue health insurance coverage for up to 18 months after a "qualifying event."
Ogletree Deakins • May 13, 2014
As part of its continuing efforts to update the sleepier corners of the employee benefits world to conform to the Patient Protection and Affordable Care Act (ACA), the U.S. Department of Labor (DOL) recently proposed new regulations of the Consolidated Omnibus Budget Reconciliation Act (COBRA) that likely herald more frequent adjustments to the model notice and election forms we all know and love. While employers have been and will continue to be free to craft customized COBRA notices, the new model notices supplied by the DOL offer a helpful leg up for the drafting process. They also provide employers with a safe harbor that is deemed to capture the substantive content mandated by COBRA.
Jones Walker • June 21, 2010
The American Recovery and Reinvestment Act provided a 65% COBRA premium subsidy to eligible individuals
involuntarily terminated between September 1, 2008, and December 31, 2009. Congress later extended the subsidy three
times; most recently for those involuntarily terminated on or before May 31, 2010. (For information regarding the
original COBRA subsidy and the previous extensions, please see our archived E*Bulletins from April 2010, March 2010,
January 2010, March 2009, and February 2009.)
Jones Walker • April 21, 2010
On April 15, 2010, Congress passed, and the President signed, the Continuing Extension Act of 2010. The Continuing
Extension Act of 2010 extends the existing 65% COBRA premium subsidy for employees who are involuntarily
terminated through May 31, 2010. The subsidy was originally provided through December 31, 2009, under the American
Recovery and Reinvestment Act (“ARRA”), and was previously extended through February 28, 2010, and then March 31,
2010, via the 2010 Department of Defense Appropriations Act and the Temporary Extension Act of 2010, respectively.
For information regarding the original COBRA subsidy and the previous extensions, please see our archived E*Bulletins
from March 2010, January 2010, March 2009, and February 2009.
Ogletree Deakins • March 11, 2010
Newly-enacted legislation extends and expands the 65 percent federal COBRA subsidy under the American Recovery and Reinvestment Act (ARRA) in cases of involuntary termination of employment. A stopgap measure signed into law on March 2 by President Barack Obama extends the end of the eligibility period from February 28 to March 31, 2010, and makes other longer-lasting changes to the year-old subsidy arrangement. These changes include: