A new IRS and DOL notice, EBSA Disaster Relief Notice 2020-01, provides temporary relief from COBRA and health plan deadlines during the COVID-19 pandemic.
What is the timeline in the DOL notice?
The notice addresses the time period from the beginning of the pandemic to 60 days after the end of the pandemic. The beginning of the pandemic is regarded as March 1. The 60 days after the pandemic ends is defined as the “Outbreak Period”. The federal government determines the Outbreak Period.
What extensions does the DOL notice provide?
Extensions for Participants
- How much time a participant has to enroll in coverage under a health plan
- How much time a participant has to pay for COBRA continuation coverage and dispute denials of claims for benefits
- The amount of time a participant has to submit claims for coverage, including the run-out period for FSA and HRA plans
- Special health plan enrollment period extensions
- How much time a participant has to notify a health plan of a qualifying event or disability
Extensions for Group Health Plan Sponsors or Administrators
- How much time a group health plan sponsor or administrator has to provide a COBRA election notice
Once the Outbreak Period ends, the actions above will resume as usual. BRI is awaiting further information and direction related to the DOL notice.
For more information, consult the COVID-19 FAQs for Participants and Beneficiaries FAQs from the Department of Labor.
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