Vigilant Blog

Yesterday, the President signed into law a bill extending the COBRA premium subsidy (yet again!) though May 31, 2010 (Legal Guide, “COBRA Provisions of the American Recovery and Reinvestment Act of 2009” (

FAQs on their website about the COBRA subsidy. For further information, see our Legal Guide, “COBRA Provisions of the American Recovery and Reinvestment Act of 2010” (

model COBRA subsidy notices, which include information on the recent changes brought about by the Temporary Extension Act of 2010. In addition to updating existing notices, the DOL also issued a new “6015).

HR 3590), a landmark health reform bill, which will now move to the President’s desk for signature. At the same time, the Health Care and Education Affordability Reconciliation Act of 2010 (  Heath benefit exchange: Health benefit exchanges will be established through which individuals and small businesses with up to 100 employees can purchase coverage….

Did you receive a 401(k) plan questionnaire from the IRS recently? If so, you’re now a part of a new IRS compliance initiative to determine the extent to which employers are complying with 401(k) rules, correcting errors and utilizing IRS compliance tools. The questionnaires were sent out to a random selection of employers, beginning in…

HR 4691) (TEA), extending the COBRA subsidy, yet again. The TEA extends eligibility for the subsidy to involuntary terminations occurring through March 31, 2010, and redefines “assistance eligible individuals” (AEIs) to include COBRA qualified beneficiaries that experience a reduction in hours on or after September 1, 2008, followed by an involuntary termination that occurs on…

model notice for employers to use in notifying employees about group health plan premium assistance available under state Medicaid programs or the Children’s Health Insurance Program (CHIP), as required by the Children’s Health Insurance Program Reauthorization Act of 2009. Employers must give the notice to all employees, regardless of whether they are enrolled in the…

Under recently finalized IRS regulations, employers who maintain ERISA-covered group health plans must self-report excise taxes that are owed to the IRS due to failure to comply with laws such as COBRA, HIPAA, and other federal laws affecting group health plans (

  6015). And stay tuned for more on the COBRA subsidy—there is legislation introduced in Congress that, if passed, would extend the COBRA subsidy eligibility and would create more transition and notice issues. Vigilant will keep members informed.  

IRS COBRA Questions and Answers: Reporting and Documentation (online Q&A RD-6, posted 1/20/10).) Tips:In other COBRA news, the U.S. Department of Labor has released 6015)  

75 Fed Reg 2068, January 14, 2010). There is no safe harbor for larger plans, so contributions should be deposited into the plan as soon as possible. Depending on a government enforcer’s assessment, “as soon as possible” for a larger plan could require a speedier deposit, or it could be as late as the 15th…