The American Rescue Plan Act (“ARPA”) requires the full cost of COBRA premiums to be subsidized for COBRA continuation coverage during the period from April 1, 2021 through September 30, 2021 (“Subsidy Period”) of certain assistance-eligible individuals (“AEI“) whose COBRA qualifying event was due to an involuntary termination or reduction in hours. Our prior blog post, COBRA Premium Assistance Under the American Rescue Plan Act of 2021 – What Employers Should Know, provides information about the ARPA COBRA subsidy and associated notice requirements. ARPA also required employers to comply with certain notice obligations, first at the outset of the Subsidy Period to make the AEIs aware of the subsidy, and now to inform AEIs that the subsidy is nearing expiration through what is known as the Notice of Expiration of Period of Premium Assistance (“Expiration Notice”).

Continue Reading Reminder: ARPA COBRA Subsidy Expiration Notice Due by September 15

As the number of confirmed positive cases of Coronavirus Disease 2019 (“COVID-19” or “coronavirus”) in the U.S. continues to rise, employers must prepare for issues that will inevitably arise as the virus spreads.  While the Center for Disease Control (“CDC”) currently advises that “most people in the United States will have little immediate risk of exposure,” it is prudent for employers to evaluate their organizations’ current policies and practices in the event a major outbreak occurs.  Some issues to consider include the following:
Continue Reading What Employers Need To Know To Prepare For Coronavirus