Authored by Larry Grudzien
Last year, several governmental agencies issued a joint notice, providing additional relief to certain employee benefit plan deadlines. The relief, effective March 1, 2020, extended the time frames of these deadlines on ERISA plans, creating an “Outbreak Period”. This relief affected:
- Special Enrollment period time frames
- COBRA election and payment time frames
- COBRA notices
- Claim procedure time frames
- External review process time frames
Under federal law, the Outbreak period cannot exceed one year. The Department of Labor has provided the following Outbreak Period Guidance:
- Began on March 1, 2020
- Continues until the earlier of one year from the date they were initially eligible or 60 days after the announced end of the COVID-19 National Emergency (or another date announced in a future notification).
- Separate from the public health emergency declared by the Department of Health and Human Services, which expires after 90 days unless an extension is issued. The most recent extension lasts through April 20, 2021
Employers should distribute the Important Notice on Outbreak Period to employees, terminated employees within their COBRA election period, and COBRA participants.
Larry Grudzien can be reached at (708) 717-9638 or via e-mail at email@example.com.
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