COVID-19 Relief Extends Certain Employee Benefit Plan Deadlines

May 04

On April 28, 2020, the Departments of Labor (DOL) and the Treasury (Departments) issued deadline relief to help employee benefit plans, plan participants and plan service providers impacted by the COVID-19 outbreak.

The Compliance Overview summarizes the participant deadline extensions affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims and external review of certain claims.

There are eight benefit time frames that have been temporarily extended to 60 days after the end of the COVID national emergency.  The eight deadlines include:

1. HIPAA Special Enrollment Period

2. COBRA Election Period

3. COBRA Premium Payments

4. COBRA Notices – Qualifying Events

5. Benefit Plan Claims Filing Procedure Timeframe (FSA/HRA)

6. ERISA Adverse Benefit Determination Appeals Deadline

7. ERISA External Review

8. Deadline to Submit Additional Information for External Review

The end of the national emergency has yet to be determined.  

Our FSA partner Navia has also put together an easy to read web page with good illustrations that explain the new timelines.  You can view the web page at: 

Governor Inslee announced today that WA will start a phased approach to reopening the State.  Details are lacking.  More information is available at:

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