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<< Older News  |  April 12, 2021

News

All News > COBRA

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Editor's Pick Managing Alternative Coverage and COBRA Coverage
Proskauer Rose, for HR Daily Advisor Link to more items from this source
Apr. 12, 2021

"There are two significant obstacles to advising employers in these situations: [1] The group health plan document (if there is one) is typically silent on the interplay between COBRA and alternative coverage; and [2] the available regulatory and case law guidance is not nearly specific enough. This column will summarize the possible approaches that employers may follow when dealing with alternative coverage situations."

Tags: COBRA  •  Health Plan Administration

DOL Issues Guidance on the American Rescue Plan Act COBRA Subsidy
Littler Link to more items from this source
[Guidance Overview]
Apr. 12, 2021

"The newly released FAQs ... do not address whether the ARPA subsidy will cover medical, dental and vision coverage or just medical coverage. They also do not clarify when a particular termination of employment should be considered voluntary[.]"

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

COBRA Subsidies Are Revived, But Include Unanswered Questions
Nelson Mullins Link to more items from this source
[Guidance Overview]
Apr. 12, 2021

"Do assistance eligible individuals include individuals with 29-month or 36-month COBRA triggers? ... Who has the obligation if there was a purchase or sale of a business? ... What if the employer is no longer subject to COBRA? ... Is ARPA subsidized COBRA limited to medical only?"

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

COBRA Subsidy Effects on Severance Programs and Employee Separations
Frost Brown Todd LLC Link to more items from this source
[Guidance Overview]
Apr. 9, 2021

"Employers that pay for a terminated employee's COBRA premiums as part of a severance program should understand that in most cases, during the next six months, this will no longer be a benefit which can serve as adequate consideration for a release of claims.... Employers should review recent and current severance and separation issues and implement [certain] changes."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Text of EBSA Notice of the Availability of the Model Health Care Continuation Coverage Notices Required by the American Rescue Plan Act of 2021
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL] Link to more items from this source
[Official Guidance]
Apr. 9, 2021

"These model documents include an ARP General Notice, a Notice in Connection with Extended Election Periods, an Alternative Notice, and a Notice of Expiration of Period of Premium Assistance.... [T]he Department also developed a Summary of ARP requirements to include the following supplemental disclosures, which should be included with the ARP General Notice, the Alternative Notice, and the Notice in Connection with Extended Election Periods: [1] A summary of the ARP's premium assistance provisions. [2] A form to request the premium assistance under the ARP. [3] A form for an individual to use to satisfy the ARP's requirement to notify the plan (or issuer) that the individual is eligible for other group health plan coverage (other than coverage consisting of only excepted benefits, coverage under a health FSA, or coverage under a QSEHRA) or that the individual is eligible for Medicare.

'Each model notice is designed for a particular group of qualified beneficiaries. When provided in combination with these supplemental disclosures, these model documents contain all of the information needed to satisfy the content requirements for the ARP's notice provisions."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Immediate Employer Action Required as DOL Issues Guidance, Model Notices for ARPA COBRA Subsidies
McAfee & Taft Link to more items from this source
[Guidance Overview]
Apr. 9, 2021

"[1] You should notify affected individuals of the one-year COBRA extension ... [2] For those [who lost] coverage between April 1, 2021 [and] September 30, 2021, you need to give them a notice regarding the free COBRA ... [3] You need to send a notice by May 31, 2021 to qualifying individuals who had a COBRA event before April 1, 2021 -- including expired COBRA participants ... [4] Free COBRA reimbursed directly to the employer ... [5] No one-year extension of deadline to elect free COBRA."

Tags: ARPA  •  COBRA

DOL Takes First Bite at COBRA Subsidy Guidance
Groom Law Group Link to more items from this source
[Guidance Overview]
Apr. 9, 2021

"The guidance does not specifically address the deadline to send updated COBRA election notices describing the subsidies for individuals with qualifying events on or after April 1, 2021 ... The election of subsidized COBRA coverage does not cut off an individual's pre-existing COBRA election right if it was extended under the Joint Relief and EBSA Disaster Relief Notice 2021-01."

Tags: ARPA  •  COBRA

DOL Issues FAQs, Model Notices for ARPA COBRA Premium Assistance
Ballard Spahr LLP Link to more items from this source
[Guidance Overview]
Apr. 9, 2021

"[T]he FAQs offer no specific guidance on the coordination of the COBRA subsidy with severance plans ... Similarly, the guidance is silent as to what constitutes an involuntary termination of employment."

Tags: ARPA  •  COBRA

DOL Issues Guidance on COBRA Subsidy
Graydon Link to more items from this source
[Guidance Overview]
Apr. 8, 2021

"One of the most important questions answered by the new FAQs helped address how the subsidy interacts with the previous guidance providing extensions to elect COBRA or pay for COBRA coverage.... The FAQs further clarified that the subsidy election period does not cut off an individual's pre-existing right to elect COBRA continuation coverage, including under the extended time frames provided under the Joint Notice and [EBSA Disaster Relief Notice 2021-01]."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Model ARPA COBRA Notices Have Arrived!
Jackson Lewis P.C. Link to more items from this source
[Guidance Overview]
Apr. 8, 2021

"While this guidance answers important questions on the administration of the subsidies, it does not ... cover important nuances such as what is an 'involuntary termination' in order to qualify for subsidized coverage, how existing separation agreement commitments to subsidize COBRA should be viewed, or details on how the corresponding payroll tax credit will work."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

COBRA Subsidy Forms and Guidance Issued
Jackson Walker Link to more items from this source
[Guidance Overview]
Apr. 8, 2021

"While the Model Notices are available, they are not mandated and can be modified. There may be good reasons for an employer to consider modifying the notices. If an employer chooses to draft their own forms or modify the model forms, the FAQs specify what information must be included in the notices."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

DOL Issues COBRA Subsidy Model Notices
Graydon Link to more items from this source
[Guidance Overview]
Apr. 8, 2021

"[T]he DOL clarified that the COVID relief on timing of providing notices under EBSA Disaster Relief Notice 2021-01 does not apply to the notice and election periods related to the COBRA subsidy of ARPA.... [U]ltimately the penalties for non-compliance are on you as the plan sponsor even if you are using a third-party COBRA administrator."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Text of DOL Model Notices for COBRA Premium Subsidy
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL] Link to more items from this source
[Official Guidance]
Apr. 7, 2021
  • Model General Notice and COBRA Continuation Coverage Election Notice: MS Word and PDF
  • Model Notice in Connection with Extended Election Period: MS Word and PDF
  • Model Alternative Notice: MS Word and PDF
  • Model Notice of Expiration of Premium Assistance: MS Word and PDF
  • Summary of COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021: MS Word and PDF

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Text of DOL FAQs About COBRA Premium Assistance Under the American Rescue Plan Act of 2021 (PDF)
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL] Link to more items from this source
[Official Guidance]
Apr. 7, 2021

10 pages. "Set out [in this document are 21 Frequently Asked Questions (FAQs)] regarding implementation of certain provisions of [ARPA], as it applies to [COBRA].... [T]hese FAQs answer questions from stakeholders to help individuals understand the law and benefit from it, as intended. The Department of the Treasury and the [IRS] have reviewed these FAQs, and, concur in the application of the laws under their jurisdiction as set forth in these FAQs."

Tags: ARPA  •  COBRA

If You Quit, You Might Not Get the COBRA Subsidy
Holland & Hart LLP Link to more items from this source
[Guidance Overview]
Apr. 7, 2021

"Does the subsidy only apply to somebody who was terminated or had hours reduced due to COVID-19? ... Does the subsidy apply to an involuntary termination even if the termination was for 'cause' for a clear performance issue? ... Is an employee who loses coverage after a certain number of months on disability or leave of absence, or due to termination after a period of disability or leave, eligible for the subsidy?"

Tags: ARPA  •  COBRA

ARPA COBRA Subsidy: Two Bites at the Apple, and Some Additional Food for Thought
Proskauer Link to more items from this source
[Guidance Overview]
Apr. 5, 2021

"[I]ndividuals making an election will have an opportunity to elect COBRA coverage on a retroactive basis (back to their loss of coverage) or on a prospective basis (starting April 1, 2021) ... While the COBRA subsidy is available for state law continuation coverage ... the special second election period ... may be limited to periods of continuation coverage provided under federal COBRA."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

COBRA Subsidies Under the American Rescue Plan Act
Kelley Drye & Warren LLP Link to more items from this source
[Guidance Overview]
Apr. 5, 2021

"AEIs who elect COBRA during this special election period will begin COBRA coverage on April 1, 2021, but if the COBRA event occurred before this date, the coverage will still end 18 months from the date they originally became eligible for COBRA.... [To] take advantage of the subsidy, they must make their COBRA elections within the special election period."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Health and Welfare Benefits Monthly Update (PDF)
Alston & Bird Link to more items from this source
[Guidance Overview]
Apr. 2, 2021

19 presentation slides. Topics: [1] IRS guidance delaying 1040 filing date (impact on HSAs) and addressing PPEs; [2] Legislative and regulatory update; [3] ARPA DCAP increase to $10,500; [4] Outbreak notice reminders and implementation issues; [5] ARPA: a deeper dive on COBRA subsidies; [6] HIPAA update.

Tags: COBRA  •  Dependent Care  •  HSAs  •  Health Plan Design

COBRA Changes Under the American Rescue Plan Act of 2021
Spencer Fane Link to more items from this source
[Guidance Overview]
Apr. 2, 2021

"The ARPA subsidy also applies to fully insured group health plans that are not subject to COBRA (e.g., because the employer typically employs fewer than 20 full-time employees), but which are subject to state continuation laws. For those plans, the insurer must provide the subsidy and is entitled to claim the tax credit."

Tags: ARPA  •  COBRA

The American Rescue Plan Keeps the FFCRA Voluntary But Expands Paid Leave
Epstein Becker Green Link to more items from this source
[Guidance Overview]
Apr. 2, 2021

"Employers covered by relevant federal, state, and/or local leave laws, including any recently enacted emergency leave laws, should evaluate how, if at all, those laws interact with paid leave benefits provided under the Act."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)  •  FFCRA  •  FMLA and Other Leave

'Free' COBRA for Some Employees: Employers May Benefit, Too
Berry, Dunn, McNeil & Parker, LLC Link to more items from this source
[Guidance Overview]
Apr. 1, 2021

"[It] appears that employers would claim the credit on their quarterly IRS Form 941 or in advance on IRS Form 7200 if the actual or estimated amount of the credit exceeds the employer's Medicare taxes for any calendar quarter.... Social Security taxes may not be available as a source for the new COBRA tax credits, since the ARP was enacted under budget reconciliation rules which prohibit any changes to Social Security."

Tags: ARPA  •  COBRA

No Fooling Around: New Six-Month COBRA Subsidy Starts April 1, Requires Immediate Action
Brownstein Hyatt Farber Schreck LLP Link to more items from this source
[Guidance Overview]
Apr. 1, 2021

"[O]nly the portion of the COBRA premium otherwise payable by an AEI is eligible for the subsidy. This means that any additional subsidy voluntarily provided by a plan sponsor is ignored ... [P]lan sponsors will need ... to make certain that there otherwise is adequate consideration for any applicable separation agreements entered into by a terminating employee."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

Editor's Pick COBRA Subsidies in COVID-19 Rescue Plan Require Employer Action
Mercer Link to more items from this source
[Guidance Overview]
Apr. 1, 2021

"The COBRA subsidy program requires immediate employer action, including creating subsidy-related notices, coordinating with vendors and insurers, revising COBRA notice and payroll processes, and deciding whether to offer subsidy-eligible individuals the option to move to less expensive coverage. Important dates are noted in [a] timeline."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)

DOL Guidance Clarifies Expiration of COVID-19 Deadline Extension for Employee Benefit Plans
Ogletree Deakins Link to more items from this source
[Guidance Overview]
Apr. 1, 2021

"The IRS also indicated in informal conversations that individuals will continue to be entitled to regulatory relief as long as they experience a deadline-triggering event during the national emergency period, even if the event occurs on March 1, 2021, or later."

Tags: COBRA  •  Coronavirus (COVID-19)  •  Health Plan Administration  •  Retirement Plan Administration

Summary of Key Provisions Within the American Rescue Plan Act of 2021
GrayRobinson, P.A. Link to more items from this source
[Guidance Overview]
Mar. 31, 2021

"ARPA expands voluntary paid sick leave availability by adding two additional qualifying reasons to the six existing qualifying reasons for EPSL.... ARPA also considerably expands EFMLA leave beyond the sole qualifying reason of caring for a child due to a COVID-19 related school closure or unavailability of childcare."

Tags: ARPA  •  COBRA  •  Coronavirus (COVID-19)  •  FMLA and Other Leave


<< Older News  |  April 12, 2021

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