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Health and Welfare Plans 2022 Update

USA - June 7 2022 The U.S. Department of Health and Human Services (HHS), along with the Internal Revenue Service (IRS) and U.S. Department of Labor (DOL), issued the…

Michael T. Bindner

What’s in the 86 COBRA subsidy Q&As released by the IRS?

USA - June 15 2021 The Notice confirms that an Assistance Eligible Individual (AEI) is an employee that is COBRA eligible between April 1 and September 30, 2021 due to…

New DOL Rule Withdraws Trump-era Employee v. Independent Contractor Test in Favor of Historic Seven-Factor Test

USA - May 14 2021 On May 6, 2021, the U.S. Department of Labor (DOL) issued a final rule that withdraws a Trump-era approach to categorizing workers as employees or…

Edward I. Rivin, Neal Shah

COBRA Subsidy Effects on Severance Programs and Employee Separations

USA - April 9 2021 The American Rescue Plan Act of 2021 (ARPA) was signed into law on March 11, 2021. The ARPA, among other things, makes significant changes to COBRA…

Irina V. Strelkova, Deborah Holland Tudor

The Return of COBRA Subsidies: Flashbacks of 2009

USA - March 19 2021 The $1.9 trillion American Rescue Plan Act of 2021 (“Act”) was signed into law by President Joe Biden on March 11, 2021. Similar to the COBRA premium…