The normal difficulties that employers have adhering to the technical requirements of COBRA have been exacerbated during the past two years as COBRA rules were changed to recognize the complications accompanying the COVID-19 pandemic. This added complexity is particularly worrisome as an employer’s simple oversight in administering COBRA can result
Articles about the federal Consolidated Omnibus Budget Reconciliation Act (COBRA)
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 the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) and initial and subsequent premium payments.
Impending Sunset of ARPA’s COBRA Subsidy & Notice Requirements
As discussed in previous HRW Client Alerts on March 16, 2021 and April 12, 2021, a provision of the American Rescue Plan Act (ARPA) requires employers to pay COBRA premiums for “Assistance Eligible Individuals” (employees who lost group health coverage due to reduced hours or involuntary termination).
It’s Not Over ‘Til It’s Over: The COBRA Premium Subsidy is Ending
As we mentioned in our May 23, 2021, article, the American Rescue Plan Act of 2021 (ARPA) provides a 100 percent premium subsidy for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA) between April 1 and September 30, 2021, for certain assistance eligible individuals (AEIs). A part of
The End of a (Short) Era: ARPA COBRA Subsidies and the Remaining Action Item for Plan Sponsors
The American Rescue Plan Act of 2021 (“ARPA”) kept many practitioners busy this spring/summer, as may be evident by our discussions here, here, here, and here.
Under one of ARPA’s most impactful provisions, employees who were involuntarily terminated or had their hours reduced (and who met certain other criteria) became
IRS Issues Additional Guidance on the COBRA Subsidy
On July 26, 2021, the Internal Revenue Service (IRS) released Notice 2021-46 to provide additional guidance on the Consolidated Omnibus Budget Reconciliation Act (COBRA) subsidy under the American Rescue Plan Act of 2021 (ARPA). On May 18, 2021, the IRS released Notice 2021-31 to address issues related to subsidy eligibility
IRS Issues Guidance on the American Rescue Plan Act COBRA Subsidy
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 group health coverage under COBRA from April 1, 2021 through September 31,
IRS Provides Clarity on ARPA COBRA Subsidy Impact on State “Mini-COBRA” Plans
In our most recent summary of IRS Notice 2021-31, we noted the Internal Revenue Service provided much-needed clarity to looming compliance challenges as employers, insurers, and others race to implement the applicable COBRA premium subsidy provisions of the American Rescue Plan Act of 2021 (ARPA). While there are many other
The New IRS COBRA Subsidy Guidance: Key Takeaways for Employers
The American Rescue Plan Act of 2021 (ARPA) implemented a 100 percent COBRA subsidy for certain qualified beneficiaries beginning on April 1, 2021, and ending September 30, 2021. On May 18, 2021, more than a month into the subsidy period, the Internal Revenue Service (IRS) released Notice 2021-31. This guidance,
Reminder – ARPA COBRA Notice Deadline Approaching; IRS Provides Much-Needed Guidance
As noted in our previous alerts regarding the American Recovery Plan Act (ARPA) COBRA subsidies and return to work issues, employers have until May 31, 2021, to notify “Assistance Eligible Individuals” of their potential right to subsidized COBRA coverage during the six-month period from April 1 to September 30, 2021
The IRS Releases FAQ Guidance on Premium Assistance for COBRA Coverage
On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 which contains much anticipated guidance needed to implement the COBRA subsidy provisions included in the American Rescue Plan Act of 2021 (ARPA).
COBRA Subsidy: You’ve Got Questions … We’ve Got Answers
The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it applies for the period from April 1, 2021, to September 30, 2021. The U.S. Department of Labor
The ARPA COBRA Premium Subsidy – The List of Must Do’s
Introduction. In mid-March, President Biden signed the American Rescue Plan Act of 2021 and included in its many provisions for providing COVID relief and economic stimulus is the six-month COBRA Premium Assistance (a/k/a COBRA subsidy).
DOL Issues Guidance, Including Model Documents, for Implementing ARPA’s COBRA Subsidy
As discussed in our recent client alert on the new COBRA subsidy, a provision of the American Rescue Plan Act (ARPA) requires employers to pay COBRA premiums for eligible employees who lost group health coverage due to reduced hours or involuntary termination and employers will receive a reimbursement in the form of a tax credit on their quarterly tax payment. This subsidy is available for 6 months, from April 1, 2021 to September 30, 2021, but does not extend the normal 18-month period for COBRA coverage. Given the administrative challenges the ARPA COBRA subsidy presents to employers, on April 7, 2021 the Department of Labor (DOL) issued guidance and model notices for implementing the provision’s requirements.
What Employers Need To Know about the American Rescue Plan Act of 2021 COBRA Subsidy
On March 11, 2021, President Biden signed the $1.9-trillion COVID-19 relief package, American Rescue Plan Act of 2021 (ARPA), into law. ARPA included a number of provisions that address COVID-19-related employment issues, including a 100-percent Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) subsidy to provide assistance to eligible individuals (AEI). This subsidy applies to medical, dental, and vision plans, however, it does not apply to health flexible spending accounts.