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Special thanks to guest contributors Christopher Guldberg and Janel Brynda.

The American Rescue Plan Act of 2021 (the “ARPA”), was signed into law on March 11, 2021, and creates a temporary COBRA premium subsidy for certain qualifying individuals. This COBRA premium subsidy applies to all group health plans subject to the Employee Retirement Income Security Act of 1974.  Thus, most employers will be impacted by the new COBRA subsidy.

Employers will need to evaluate the impact of the ARPA not only with respect to COBRA administration, but equally important,  employers may need to make changes to their severance arrangements to take into account the temporary COBRA subsidy.

The ARPA provides that an assistance eligible individual who elects COBRA coverage will be deemed to have paid 100% of any applicable COBRA premium (including the 2% administrative charge) during the period April 1, 2021 to September 30, 2021. In this respect, ARPA differs from the premium assistance under the American Recovery and Reinvestment Act of 2009 that only provided for a partial premium subsidy for eligible individuals.


Continue Reading The American Rescue Plan of 2021 Requires Employer Action and Potential Updates to Severance Arrangements

Special thanks to guest contributors Monica Kurnatowska, Bernhard Trappehl and James Brown.

In brief

The EU Commission has proposed a directive that would reinforce the entitlement to equal pay for men and women for the same work, or work of equal value, including by giving employees the right to comparative pay information and by requiring gender pay gap reporting for employers with 250+ employees, amongst other measures. Some EU member states already have aspects of these rules, while others do not, meaning that the rules could be a significant additional compliance burden for some organisations. The rules, if adopted, would be unlikely to come into force before late 2024.

Key takeaways

The EU Commission has proposed a new directive on pay transparency. If adopted, it would:

  • Require measures to ensure employers pay the same work, or work of equal value, equally.
  • Require employers to provide initial salary (or salary range) information to job applicants, pre-interview.
  • Prohibit employers from asking job applicants about salary history.
  • Create a right for a worker to request information about:
  • Their own pay level
  • Average pay levels, broken down by gender and categories of workers doing the same work / work of equal value
  • Require gender pay gap (GPG) reporting for employers with 250+ employees.
  • Create joint pay assessments if:
  • GPG is 5%+ for any category of workers doing the same work or work of equal value, and
  • employer has not justified the GPG.

Based on previous experience, we estimate that these proposals, if adopted, would need to be implemented by sometime in late 2024.


Continue Reading European Union: Commission Proposes Pay Transparency Rules to Secure Equal Pay

Special thanks to our guest contributors Melissa Allchin and Sandhya Sharma.

In this Mobility Minute, our Global Immigration and Mobility attorneys look at the significant change in who may qualify for travel to the US from the Schengen Area, United Kingdom and Ireland after the revocation of National Interest Exceptions for certain business travelers,

Special thanks to our guest contributors Matthew Gorman and Cristina Messerschmidt.

In this Mobility Minute, our Immigration and Data Privacy lawyers will be looking at the issue of data privacy, or lack thereof, at US ports of entry, including international airports. We will review a recent court decision that appears to further minimize protections

Special thanks to our guest contributors David Serwer and Alessandra Faso.

In this Mobility Minute, our Global Immigration and Mobility attorneys discuss the prospects for comprehensive immigration reform given the introduction of the U.S. Citizenship Act of 2021, as well as the Biden Administration’s choice of immigration as its first major legislative battle after

Special thanks to our guest contributor Daniel Urdiain.

In this Mobility Minute, Daniel Urdiain of our Mexico Global Immigration and Mobility practice explores the continuing challenges for those submitting immigration filings in Mexico City, as well as the current alternatives to conclude the process in the shortest amount of time.

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Special thanks to our guest contributors Anne Batter, Alexandra Minkovich, Joshua Odintz, Christopher Hanna, Etienne Couret and Derek Gumm.

After months of partisan bickering and Senate inaction, Congress finally passed another round of COVID-19 relief legislation as part of the Consolidated Appropriations Act, 2021, P.L. 116-260, (“CAA”), which was signed

Special thanks to our guest contributors Ginger Partee and John Foerster.

In this Mobility Minute our Global Immigration and Mobility attorneys discuss changes to the H-1B program under the Biden Administration. We will quickly review what was the final rule under the Trump Administration and provide insight on the new final rule, including practical