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 relief, a qualified beneficiary may wait one year to elect COBRA and then wait another year to make their
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U.S. Department of Labor Steps into the Cybersecurity Discussion
Formally wading into the cybersecurity discussion for the first time, on April 14, 2021, the U.S. Department of Labor (DOL) posted on its website a suite of new guidance, including Tips for Hiring a Service Provider with Strong Cybersecurity Practices, Cybersecurity Program Best Practices, and Online Security Tips for Participants and Beneficiaries.…
ARPA COBRA Subsidy – Special Second Election Period (Two Bites at the Apple and Some Additional Food for Thought)
The American Rescue Plan Act of 2021 (“ARPA”) provides a 100% COBRA premium subsidy for “assistance eligible individuals” for periods of coverage occurring between April 1, 2021 and September 30, 2021, as summarized here. An “assistance eligible individual” includes any qualified beneficiary who is eligible for COBRA coverage as a direct result of a…
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 earlier blog posts. An “assistance eligible individual” is any COBRA “qualified beneficiary” who loses group health coverage on account of…
ARPA COBRA Subsidy – When is a Termination of Employment Involuntary?
As we previously explained in our prior blogs, both here and here, on the new COBRA subsidy rules, the American Rescue Plan Act of 2021 (“ARPA”), includes a 100% COBRA premium subsidy for periods of coverage occurring between April 1 and September 30, 2021. The subsidy is available to qualified beneficiaries who are eligible…
The ARPA COBRA Premium Subsidy
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 September 2021 for employees (and their family members) who experience a loss of group health coverage due to…
COVID-19 Stimulus Bill to Include Significant Pension Reforms and Expand Scope of 162(m) Compensation Deduction Limit
Today, the House of Representatives passed the $1.9 trillion American Rescue Plan Act of 2021 (the “ARPA”). The ARPA has already been approved by the Senate and is expected to be quickly signed into law by President Biden. We recently published a client alert addressing Title IX, Subtitle H of the new legislation, which includes…
We Now Know For Whom the Statute Tolls
In our February 12th blog post, we raised the question of how to interpret the duration of the DOL/Treasury relief tolling certain benefit plan deadlines due to the COVID-19 pandemic. Without guidance from the agencies, it was unclear whether the relief was set to expire in a few days (on February 28, 2021) due…
Additional Relief for FSA Benefits
As part of the COVID-19 relief package passed by Congress earlier this week, which has not yet been signed into law by President Trump, the federal government expands on earlier relief issued by the Internal Revenue Service (IRS) for health and dependent care flexible spending account benefits (FSAs). Under these temporary rules, plan sponsors may…