“Update: IRS and DOL Issue Guidance on COBRA Changes”

The Internal Revenue Service and the Department of Labor have released additional guidance (the “Guidance”), in the form of Q&As that are intended to clarify some of the interpretative issues associated with these changes. In light of the strict deadlines for compliance with the COBRA changes, which require immediate action on the part of most employers, we are circulating this Stroock Special Bulletin to make clients and friends of the Firm aware of this Guidance as soon as possible.