The Employee Benefits Security Administration and the Internal Revenue Service have provided relief to certain plan participants, which plan sponsors and administrators will be required to implement. Essentially, the plan must disregard the coronavirus “Outbreak Period” when it is calculating certain plan deadlines. The Outbreak Period runs from March 1, 2020, until sixty (60) days after the announced end of the National Emergency (or such other date announced by the agencies in a future notice). In the event there are different Outbreak Period end dates for different parts of the country, the agencies will issue additional guidance regarding this relief. This extension impacts deadlines for the following:
- HIPAA Special Enrollment under a group health plan;
- COBRA elections, premium payments, and notice of certain changes; and
- Claims and appeals under the plan (applicable to both retirement and welfare plans).
Click here to view charts describing how this extension works for several of the deadlines. For illustration only, we assume that the announced end of the National Emergency is April 30, 2020.