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IRS Guidance Clarifies “Involuntary Termination” for the COBRA Subsidy

USA - June 2 2021 In Notice 2021-31, the Internal Revenue Service (IRS) provides broad guidance in a question-and-answer format on the application of the American…

B. David Joffe.

DOL Actively Enforcing Newly Required Mental Health Comparative Analysis

USA - May 18 2021 Group health plans and insurers have been required since 2008 to ensure that any “nonquantitative treatment limitations” (NQTLs) imposed on mental…

B. David Joffe.

IRS Answers Questions on Taxation of DCAPs and COVID-19 Relief

USA - May 12 2021 The Internal Revenue Service (IRS) has published Notice 2021-26 to provide answers regarding the taxability of benefits received in 2021 and 2022…

B. David Joffe.

DOL Issues Model Notices for COBRA Premium Assistance

USA - April 9 2021 As we discussed in a previous article, the American Rescue Plan Act of 2021 (ARP), provided premium assistance and an extended election period under…

Pump the “Pecuniary” Brakes: DOL Won’t Enforce the New Rule on Financial Factors in Selecting Plan Investments

USA - March 11 2021 The Department of Labor (DOL) has released a short statement announcing that it will not enforce the final rule on “Financial Factors in Selecting…