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Michael Chan

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Michael Chan is a partner in the Tax, Employee Benefits, and Executive Compensation Practice Groups in the firm's Los Angeles office.

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The American Rescue Plan Act (“ARPA”) requires the full cost of COBRA premiums to be subsidized for COBRA continuation coverage during the period from April 1, 2021 through September 30, 2021 (“Subsidy Period”) of certain assistance-eligible individuals (“AEI“) whose COBRA qualifying event was due to an involuntary termination or reduction in hours. Our prior blog post, COBRA Premium Assistance Under the American Rescue Plan Act of 2021 – What Employers Should Know, provides information about the ARPA COBRA subsidy and associated notice requirements. ARPA also required employers to comply with certain notice obligations, first at the outset of the Subsidy Period to make the AEIs aware of the subsidy, and now to inform AEIs that the subsidy is nearing expiration through what is known as the Notice of Expiration of Period of Premium Assistance (“Expiration Notice”).
Continue Reading Reminder: ARPA COBRA Subsidy Expiration Notice Due by September 15

The Department of Labor (“DOL”) recently issued key guidance in the form of frequently asked questions (“FAQs”) about COBRA Premium Assistance under the American Rescue Plan Act of 2021 (“ARPA”).  In addition to issuing the FAQs, the DOL issued model notices and announced a new website dedicated to the COBRA premium subsidy under ARPA, which can be found at the following link: https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra/premium-subsidy.
Continue Reading COBRA Premium Assistance Under the American Rescue Plan Act of 2021 – What Employers Should Know

Important Upcoming Registration Deadline:  California employers with more than 100 employees are required to register (or certify as exempt) with the CalSavers Retirement Savings Program (CalSavers) by September 30, 2020 (the original deadline of June 30, 2020 was extended due to the COVID-19 pandemic).  The registration deadline for California employers with 100 employees or fewer will be phased-in over the next two years.  California employers with 51 to 100 employees are required to register by June 30, 2021, and those with 5 to 50 employees are required to register by June 30, 2022.  Businesses located in California may begin to receive notices from CalSavers to register or certify an exemption for the company.  The link to the CalSavers’ website to register or to claim exemption is https://employer.calsavers.com.
Continue Reading Important CalSavers Registration Deadlines for California Employers

On March 27, 2020, President Trump signed the largest economic stimulus package in American history into law.  Although the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) made several amendments to the Families First Coronavirus Response Act (“FFCRA”), the majority of the amendments were technical corrections that do not impact the substantive provisions of the FFCRA.
Continue Reading The CARES Act: What Employers Need to Know About Its Impact on the Families First Coronavirus Response Act

In the wake of the COVID-19 pandemic, reductions in hours, furloughs and temporary closures are becoming an increasingly common and unavoidable occurrence.  Employers can expect to encounter questions with respect to employee benefits offered to affected employees.  While the facts and circumstances of each case will vary, common themes exist, a few of which are mentioned below.
Continue Reading Critical Employee Benefit Issues in a Pandemic – Can Employees Take Their Money out of Plans?