Joshua E. Stephens
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One important question that arises when determining whether an individual is eligible for the COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”) is whether the employee has experienced an involuntary termination of employment. (See our prior blogs on the ARP subsidy, here.) The IRS’s recent Notice 2021-31 (the “Notice”) provides helpful … Continue Reading
The problem of “missing” participants and beneficiaries (individuals for whom the plan administrator does not have adequate contact information) is an ongoing issue for retirement plan administrators. It is also an area to which the DOL has dedicated significant attention in recent years, particularly in its enforcement actions, which has been a challenge for administrators. … Continue Reading
A Word from the IRS on Involuntary Terminations of Employment for Purposes of the ARP COBRA Premium Subsidy
By Paul M. Hamburger, Roberta Chevlowe, Katrina McCann and Joshua E. Stephens on Posted in COBRA
DOL Releases Guidance on Addressing the Missing Participant Problem
By Mary Grace Richardson and Joshua E. Stephens on Posted in Department of Labor
