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Thomas M. White Most employers recognize that their self-insured health plans must not discriminate in favor of highly compensated employees if those benefits are to be provided on a tax free basis. However, these non-discrimination rules have not previously been applied to insured health care programs. Consequently, many employers have purchased health care policies only [...] On March 19, 2009, the U.S. Department of Labor (“DOL”) released model COBRA notices required under the COBRA provisions of the 2009 American Recovery & Reinvestment Act (“ARRA” or “Act”). As previously reported, the Act impacts COBRA coverage, and the means by which employers may claim the tax credit for COBRA subsidies paid under the [...] |
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