In this issue:
Amanda J. Dernovshek, Julie L. Hamlet and Mindi M. Johnson
There are a number of reasons why employers may want their employees to receive the COVID-19 vaccines. Such reasons may include, for example, the employer’s commitment to public health initiatives, concerns with employee health and wellbeing or satisfaction of vaccine requirements imposed by suppliers, vendors or affiliates.
If your organization is considering whether to incentivize employees to get vaccinated and/or requiring that employees prove that they have been vaccinated, there are several items to consider. Those items are summarized below...
The Employee Retirement Income Security Act of 1974 (“ERISA”) includes a whole host of obligations that apply to plan fiduciaries. An individual may qualify as a plan fiduciary to the extent that the person (1) exercises any discretionary authority over the management of the plan or (2) exercises discretionary authority over the management or disposition of the plan assets.
An individual may also qualify as a fiduciary if he or she renders investment advice regarding plan assets for a fee. Plan fiduciaries include trustees, plan administrators, and individuals that provide certain services to an ERISA plan...
The American Rescue Plan Act (“ARPA”), enacted on March 11, 2021, requires employers to fully subsidize COBRA coverage for certain individuals during the period beginning on April 1, 2021 and ending on September 30, 2021 (the “Subsidy Period”).
This article provides an overview of the COBRA subsidy provisions under the ARPA...
Last year, the U.S. Department of Labor (“DOL”) and IRS issued guidance providing that group health plans and certain other benefit plans must disregard the period beginning March 1, 2020 and ending 60 days after the announced end of the COVID-19 national emergency (the "Outbreak Period") for purposes of applying various deadlines under COBRA, ERISA, and HIPAA’s special enrollment provisions.
These deadline extensions are discussed in our prior blog article...
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