The impacts of the COVID-19 National emergency have been vast. As a result, many employers and employees are struggling to meet various filing, notice, election, or other deadlines. In order to ease the burden on employers, health plans and participants, on April 28, 2020 the Department of Labor (DOL), the Internal Revenue Service (IRS), and the Department of Health and Human Services (HHS) issued much-needed guidance and relief.
In order to ease the burden on participants and beneficiaries, the DOL, in coordination with the IRS issued a Final Rule extending certain timeframes and deadlines for participants to consider coverage elections and benefits decisions under ERISA and the Code.
Specifically, Final Rule provides plan participants, beneficiaries, qualified beneficiaries, and claimants with relief from meeting the below referenced periods and dates during the period of March 1, 2020 until 60 days after the announced end of the COVID-19 National Emergency (or such other date announced by the Agencies in a future notice):
- The 30-day period (or 60-day period, if applicable) to request a special enrollment
- The 60-day election period for COBRA continuation coverage
- The date/deadline for making COBRA premium payments
- The deadline for individuals to notify the plan of a qualifying event or determination of disability
Consistent with the above, the Final Rule provides group health plans with relief from issuing COBRA election notices for any qualifying event that occurred between March 1, 2020, and 60 days after the announced end of the COVID-19 National Emergency (or such other date announced by the Agencies in a future notice).
Employers are encouraged to familiarize themselves with the relief in the Final Rule and EBSA Notice 2020-01, work with their insurance broker, COBRA administrator or other vendors to ensure compliance with this relief, and continue to work with their employees during this difficult time.
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