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COBRA Premium Assistance Expiration Notice

As the COBRA subsidy period comes to an end on September 30, 2021, plans are required to send a notice 15 to 45 days before an assistance eligible individual’s (“AEIs”) subsidy ends.  For AEIs whose subsidy period will end on September 30th, notices must be sent no later than September 15th.  The notice must describe: […]
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“Long COVID” to Qualify as ADA Disability

Recent guidance released by the Department of Health and Human Services and the Justice Departments’ Civil Rights Division (“Joint Guidance”) confirms that people who continue to experience COVID symptoms months after first being infected may qualify as disabled under the Americans with Disabilities Act (ADA). Anyone who has had COVID-19, even where the initial illness […]
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Now Available – COBRA Subsidy Model Notices and Q&As

The American Rescue Plan Act of 2021 (“ARPA”) subsidizes the full COBRA premium for Assistance Eligible Individuals (“AEIs”) for six months between April 1, 2021 through September 30, 2021. To be eligible for this premium assistance,  the AEIs must: MUST have a COBRA qualifying event that is a reduction in hours or an involuntary termination […]
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Health Plan Administration Amid COVID-19 Disaster Relief Extensions – Employee Benefit Security Administration Disaster Relief Notice

The Department of Labor issued Notice 2021-01 on February 26, 2021 to address the expiration of the extension of certain benefit deadlines that expired on February 28, 2021. See the summary of Notice 2020-01 at the end of this blog for more information. Notice 2021-01 Notice 2021-01 confirms that the guiding principle for administering employee […]
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2020 Options for Unused Qualified Transportation Benefits Due to COVID-19

As a result of COVID-19, employees may be commuting less frequently to work, have changed their method of commuting (i.e. driving v. public transportation) or switched to telework. If your employees participate in a qualified transportation plan, they may have unused benefits. The IRS has released Information Letter 2020-2024 providing the following options for calendar […]
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Affordable Care Act Reporting for 2020

Employers face a great deal of challenges in 2020 related to COVID-19, including lock down orders, supply chain disruptions, and virtually unprecedented economic uncertainty.  The patchwork of state and federal responses to assist business, ranging from forgivable loans to deadline relief, does not currently extend to relief from the annual information reporting requirement under the […]
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IRS Notice 2020-29: Relief for Section 125 Cafeteria Plans and Flexible Spending Accounts

Background By now, employers are probably used to seeing regular updates and rule changes issued by various federal agencies including the Department of Labor and Internal Revenue Service that are in some way related to COVID-19.  Additional guidance issued on May 12, 2020 from the IRS provides relief to employees who are seeking to change […]
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FFCRA and CARES Act

FFCRA & CARES Act – Overview of Benefits Changes President Trump signed into law two major pieces of legislation aimed to provide relief in various forms to business, individuals, and government agencies – the Families First Coronavirus Response Act (“FFCRA”) and the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”).  Both laws make major […]
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