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 … Continue reading

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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 … Continue reading

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In Case You Missed It – Key 2021 Employee Benefits Topics

This year is off to a fast start and plan sponsors might find their heads spinning as they try to keep track of rapidly developing employee benefits legislation and guidance.  We periodically consolidate key newsletters and blog posts to help … Continue reading

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Arizona’s New Mini-COBRA Statute Has Arrived, but Is Preemption a Concern?

The Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) requires employers who have 20 or more employees and who offer a group health insurance plan to provide enrollees with a right to continue coverage after the occurrence of certain qualifying … Continue reading

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Health Plans – A Pain to Administer But Appreciated by Employees

Administering health plans is not the easiest task.  Such plans are subject to an alphabet soup of laws, including but not limited to ERISA, the Internal Revenue Code, COBRA, HIPAA, GINA, Mental Health Parity, the ADA, the ADEA, and Title … Continue reading

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Curing What Ails You – Relief for Small Employer HRAs

The impact of the Affordable Care Act (“ACA”) on health reimbursement arrangements (“HRAs”) has not been favorable.  Many employers got rid of their HRAs or integrated them with a major medical plan in order to avoid significant penalties under ACA.  … Continue reading

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Subsidized Post-Termination COBRA Benefits

Nancy Campbell recently wrote a newsletter that discussed how health care reform impacts COBRA. One of the issues that Nancy addressed is subsidized COBRA and severance arrangements. The purpose of this blog is to dive deeper into the issues employers … Continue reading

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