Dykema Gossett PLLC

Dykema Labor & Employment Law Blog

Posts by Amy M. Christen


Amy M. Christen
View Bio

Showing 3 posts by Amy M. Christen.

The Window Is Closing for Employers to Notify Individuals About the Expiring ARPA COBRA Subsidy

The American Rescue Plan Act of 2021 (“ARPA”) provides a premium subsidy for continuing coverage under the Consolidated Omnibus Budget Reconciliation Act (“COBRA”) for employees who lost their health insurance coverage as a result of an involuntary termination (other than gross misconduct) or a reduction of hours, known as Assistance Eligible Individuals (“AEIs”). This COBRA premium subsidy generally is available between April 1, 2021, and September 30, 2021, unless it ends earlier for AEIs who become entitled to other group health coverage or Medicare. Read More ›

Question and Answer: Employee Benefits Triage Amid COVID-19

Dykema has launched a COVID-19 Resource Center to keep our clients up to date on the most recent legal, business and health guidance surrounding the novel coronavirus and how to navigate their businesses through uncertain times. Various firm practitioners are providing timely content that aims at providing guidance for employer’s current issues as well as those unforeseen items that have yet to arise. The site is continually being updated, as state and federal authorities provide guidance on a rolling basis. Read More ›

IRS Provides Formal Guidance Regarding Delay of Employer Mandate and Employer Reporting Requirements under ACA

On July 9th, the IRS provided formal guidance in IRS Notice 2013-45 that confirms the one-year delay of the Employer Mandate (Code Section 4980H) and the employer reporting requirements (Code Sections 6055 and 6056) under the Affordable Care Act.  These delays were first announced in a blog post on the Treasury and White House websites.  You can find Dykema’s alert on the delay here.  Notice 2013-45 confirms the delay in the Employer Mandate requirements and reporting requirements but encourages employers to voluntarily comply with the reporting requirements (once regulations are issued) during 2014 so that employers are in a better position when this is fully-implemented in 2015.  The Notice confirms that this delay on the Employer Mandate and reporting requirements has no effect on any of the other provisions of the Affordable Care Act, including employees’ access to a premium tax credit or the Individual Mandate.

Please contact Amy Christen or Gabe Marinaro for additional detail or questions regarding Notice 2013-45 or any other questions regarding the Affordable Care Act.