DOL Issues Health Plan Deadline Extensions

In response to the COVID-19 outbreak the Department of Labor, in coordination with the IRS and Department of Health and Human Services (HHS), issued a notice extending certain health plan deadlines to accommodate participants and plans affected by the outbreak.   The notice requires group health plans to disregard the period from March 1, 2020 until 60 days after the announced end of the previously declared National Emergency (or such other date announced by the Agencies in a future notice) when determining what the required extensions are.  These extensions need to be taken into consideration in determining the following periods and deadlines:

1. The 44-day deadline for providing a COBRA election notice to a qualified COBRA beneficiary;
2. The 60-day COBRA continuation coverage election period;
3. The deadline for making COBRA premium payments (generally 30 days from the beginning of each month, or 45-days for the initial payment); and
4. The 60-day deadline for an employee to notify the plan of a COBRA qualifying event (such as a divorce).
5. HIPAA Special Enrollment Period for Qualified Life Events
6. Claims and Appeals Filing

The official periods and deadlines cannot be calculated until the National Emergency is declared over.  For illustrative purposes assume the National Emergency ended on April 30, 2020, that would mean plans have to disregard the period from March 1, 2020 until June 29, 2020 when calculating the extended deadlines.

We know that these are uncertain times, and we are aware that the government will continue to further guidance. GSA National’s focus is to understand the guidance and how it may impact the government contract space. We will continue to post pertinent information and are always here to address concerns. Feel free to contact us at solutions@gsanational.com and time, and a subject matter specialist will contact you shortly.