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Additional COBRA Subsidy Guidance: IRS Notice 2021-46

New guidance from IRS Notice 2021-46 (Notice) provides additional clarity on some miscellaneous requirements of the American Rescue Plan Act of 2021 regarding premium assistance for COBRA (Subsidy). See Notice 2021-46. Who is eligible for the Subsidy and for how

Peter Iverson, Esq. July 29, 2021
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401(k): Updates to EPCRS Correction Programs Encourage Employers to Self-Identify, Correct Mishaps

On July 16, 2021, the IRS issued Revenue Procedure (“Rev. Proc.”) 2021-30, the most recent comprehensive official guidance concerning the IRS’s Employee Plans Compliance Resolution System (“EPCRS”). (See our reference article entitled “401(k): EPCRS Overview” for a general discussion of

Dan Bond July 23, 2021
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FAQs Clarification: Covered Testing and Services re: PrEP

On July 19, 2021, the Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments) published a set of FAQs regarding the coverage of HIV Preexposure Prophylaxis (PrEP) as preventive care. Background The ACA requires non-grandfathered

Peter Iverson, Esq. July 19, 2021

Reminder: COVID-19 Vaccines and Employer Incentives

What’s an employer to do about it’s wellness programming respecting COVID-19 vaccinations? Exercise caution. This summer the EEOC provided guidance for employers on navigating the murky waters where the ADA, GINA, and wellness incentives intersect. Employers may offer COVID-19 vaccination

Peter Iverson, Esq. July 15, 2021
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