I was a summer associate back in 1996 when, just steps from our old offices at 1585 Broadway, people lined up for blocks outside the Nederlander Theatre in the hopes of getting tickets to the hot, new-to-Broadway show that was captivating audiences nightly. Those lucky enough to score tickets to Rent would soon get to … Continue Reading
The IRS just released some new supplemental guidance on the COBRA premium subsidy in the American Rescue Plan Act (“ARP”). IRS Notice 2021-46, released July 26, 2021 provides additional color on a handful of discrete subsidy issues that had been addressed in earlier guidance but still caused some confusion. The guidance, in Q&A format, addresses: … Continue Reading
Over the last few months, employers and plan administrators have concentrated on identifying qualifying individuals eligible for COBRA premium assistance under the American Rescue Plan Act of 2021 (“ARP”), sending out proper notices, and collecting election forms. Now that the dust has settled on the first round of election notices, employers and plans have turned … Continue Reading
As a follow up to our previous alert on the American Rescue Plan Act of 2021, we have summarized the key aspects of the recently released PBGC and IRS guidance on the new Special Financial Assistance Program for troubled multiemployer pension plans in our latest client alert, which can be found here.… Continue Reading
On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice addresses how to calculate the premium subsidy and the corresponding tax credit available to premium payees, as well as the rules … Continue Reading
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
In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice. This post revisits the topic in light of the new guidance in IRS Notice 2021-31 (the “Notice”). In general, for individuals otherwise eligible for … Continue Reading
Due to tight timelines and an initial sprint to issue the special extended COBRA election period notices by the May 31st deadline, plan administrators may not have focused on the other COBRA-related notice requirements under the American Rescue Plan Act (ARP). This blog post focuses on these other notices – for individuals who become entitled … Continue Reading
The American Rescue Plan (“ARP”) offers a special 60-day election period for certain individuals who previously declined or discontinued COBRA coverage (“Assistance Eligible Individuals” or “AEIs,” as defined in ARP). These individuals may elect COBRA coverage prospectively, beginning April 1st, at no cost, as long as they are not eligible for Medicare or other group … Continue Reading
As mentioned in our earlier posts, the American Rescue Plan Act of 2021 (“ARP”) provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible individuals (“AEIs”). As employers and plan administrators prepare to educate AEIs about this subsidy, they cannot overlook another necessary notice: a … Continue Reading
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 covered … Continue Reading
This website uses third party cookies, over which we have no control. To deactivate the use of third party advertising cookies, you should alter the settings in your browser.
