The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a payroll tax credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS confirmed that assistance-eligible individuals (AEIs) do not lose their eligibility for premium subsidy simply because they are eligible for TRICARE health coverage. TRICARE is the health care program serving active duty service members, National Guard and Reserve members, retirees, their families, survivors and certain former spouses worldwide. Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a payroll tax credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS confirmed that members of military Reserve units and National Guard are considered involuntarily terminated if they are called to active duty. This is true whether the employer treats it as a termination of employment or a leave of absence. Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a payroll tax credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS reviewed elected officials eligibility for the premium subsidy. The important distinction is whether or not the elected official is considered involuntarily terminated. The IRS considered three situations, as follows:
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An elected official who runs for reelection, but is not reelected is considered involuntarily terminated.
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An elected official prohibited by term limits from running for reelection is considered involuntarily terminated.
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An elected official who does not run for reelection, but is eligible to do so, is not considered involuntarily terminated, even if the elected official did not run due to illness.
Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS confirmed that an employee “hired only for a limited period such as a seasonal worker or a teacher hired only for one school year” is considered involuntarily terminated for premium subsidy purposes if the employee works to the end of season or contract period, is not offered employment, and is able and willing to work. Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS stated that if an insurer is providing continuation coverage under a comparable state law, the coverage still qualifies for premium subsidy even if the group health plan has terminated after the employer has gone out of business. Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS stated that when an employer voluntarily provides continuation coverage when the plan is not subject to “COBRA continuation coverage”, then the subsidy does not apply to the voluntary coverage. Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) has released Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided.
In recently issued guidance, the IRS stated that when an employer makes a “reasonable interpretation of the applicable statutory provisions and IRS guidance” while determining that an employee was involuntarily terminated, the IRS won’t challenge the determination for purposes of deciding if the employer is entitled to the COBRA premium reduction credit. The employer is required to maintain the supporting documentation to support the determination. Contact Vision Payroll if you have any questions on the COBRA premium reduction credit.
The Internal Revenue Service (IRS) recently released an advance copy of Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided. Vision Payroll provided an overview of Notice 2009-27 when it was first issued. Today we will be reviewing Additional Issues under Notice 2009-27.
The IRS indicated in Notice 2009-27 that it is aware of additional issues not addressed in Notice 2009-27. The IRS and the US Department of the Treasury are still considering these issues and may issue future guidance on them.
This concludes our summary of Notice 2009-27. Contact Vision Payroll if you have any questions on Notice 2009-27.
The Internal Revenue Service (IRS) recently released an advance copy of Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided. Vision Payroll provided an overview of Notice 2009-27 when it was first issued. Today we will be reviewing Comparable State Continuation Coverage.
Individuals who would otherwise be eligible under Federal COBRA may also qualify under comparable state laws that provide for continuation coverage for those who may not qualify under Federal COBRA. The fact the state plan has a different period of continuing coverage, different qualifying events, different qualified beneficiaries, or different maximum premiums generally does not mean the plan is not “comparable solely for those reasons.”
For plans subject solely to state law that require the insurer to provide continuation coverage, only the insurer may claim the premium reduction credit, even if the employer collects the reduced premium and pays the full premium to the insurer. The IRS left open the possibility that future guidance may change this conclusion.
The next topic covered will be Additional Issues. Contact Vision Payroll if you have any questions on Notice 2009-27.
The Internal Revenue Service recently released an advance copy of Notice 2009-27, Premium assistance for COBRA benefits. Pursuant to the American Recovery and Reinvestment Act of 2009 or ARRA, certain involuntarily terminated employees are eligible for employer-provided subsidies to help pay for their Consolidated Omnibus Budget Reconciliation Act (COBRA) continuation coverage. Employers may then claim a credit on their Form 941 to be reimbursed for the assistance provided. Vision Payroll provided an overview of Notice 2009-27 when it was first issued. Today we will be reviewing Payments to Insurers under Federal COBRA under Notice 2009-27.
For plans subject to COBRA that are not multiemployer plans and for which the insurer collects the premiums directly from the qualified beneficiaries, the insurer is required to treat the payment of 35% of the premium by assistance eligible individuals as payment of the full premium, regardless of when the employer pays the remaining 65% of the premium. Failure to do so may subject the employer to the excise tax under §4980B(e)(1)(B) of the Internal Revenue Code of 1986.
The next topic covered will be Comparable State Continuation Coverage. Contact Vision Payroll if you have any questions on Notice 2009-27.
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