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Final Touches: IRS Clarifies Impact of COVID-19 Disaster Relief on COBRA Payment Deadlines

The Internal Revenue Service recently issued guidance to clarify the interaction between COVID-19 disaster relief and premiums due for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”). As summarized here, the Joint Notice and the EBSA Disaster Relief Notice (the “Disaster Relief”) extended certain key deadlines in light of the COVID-19 […]

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Better Late Than Never: IRS Issues Guidance Clarifying COBRA Premium Subsidy Rules

S&W Insight: The IRS clarified several trailing issues with respect to COBRA premium subsidies under the American Rescue Plan Act, including extended election periods, eligibility for other coverage, and rules about allocating premium credits among employers. In addition, a notice deadline is on the horizon. Many employers have been grappling with the ramifications of the […]

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