EEOC Issues Updated Guidance on COVID-19 Vaccinations

As addressed in our prior client alert, earlier this year, the Equal Employment Opportunity Commission (“EEOC”) issued guidance for employers on how the COVID-19 vaccine interacts with federal anti-discrimination laws, such as the Americans with Disabilities Act (“ADA”), the Genetic Information Nondiscrimination Act (“GINA”), and Title VII. Employers have been eager for additional direction from the EEOC as the vaccine has become more widely available, and many employees have begun returning to the office. Last Friday, the EEOC issued additional guidance on these topics.

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Governor Cuomo Signs Hero Act

Yesterday, Governor Cuomo signed the HERO Act, which, among other things, will require employers to comply with standards issued by the Department of Labor (DOL) to prevent airborne infectious diseases in the workplace. Governor Cuomo has reportedly reached an agreement with the Legislature to make certain technical changes to the bill, including giving the DOL and employers more specific instructions for developing and implementing the workplace standards and a clear timeline.

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NYS Legislature Passes HERO Act

Last week, the New York State Legislature passed legislation focused on health and safety in the workplace. Specifically, the bill requires that the Commissioner of Labor and Department of Health create an airborne infectious disease standard for all private employers which must be disseminated to all employees. The law also permits employees to create joint employer-employee workplace safety committees to raise health and safety issues and evaluate the health and safety protocols of the workplace.

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DOL Issues Model COBRA Notices and FAQs Related to ARPA

As we discussed in our client alert, on March 11th, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”), which, among other things, requires an individual’s former employer or the insurance company (depending on the type of plan) to cover the full cost of COBRA premiums for any period of coverage between April 1, 2021 and September 30, 2021 (the “COBRA Subsidy”) for an eligible employee (generally, someone who was involuntarily separated or who had a reduction in hours). The employer or insurance company that pays these premiums may claim a tax credit to defray the cost of the premiums. ARPA also creates a Special Election Period where all individuals who lost group health insurance coverage within the past 18 months due to an involuntary separation or reduction in hours are required to receive notice of the COBRA Subsidy and their ability to elect COBRA by May 31, 2021. On April 7, the Department of Labor (“DOL”) issued the model notices as well as Frequently Asked Questions (“FAQs”) related to ARPA and COBRA.

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