Firm Publications

COVID-19 Update: IRS and DOL Extend COBRA and Other Benefit Plan Deadlines During the Pandemic Outbreak Period

May 5, 2020

On April 28, 2020, the Employee Benefits Security Administration, the Department of Labor, the Internal Revenue Service, and the Department of the Treasury (the “Agencies”) signed a joint notification of relief, which was published in the Federal Register on May 4, 2020 (the “Notice”).  The Notice provides extension of deadlines with respect to certain medical plan enrollments, election periods under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), COBRA premium payments, COBRA qualifying event notification periods, and certain plan claims, appeals and review periods.  The Notice is anticipated to have a significant impact on the administration of health plans.  The dramatically liberalized deadlines will provide much appreciated flexibility for participants, but could result in an increase in adverse selection and resulting increase in costs, as well as administrative issues for plan administrators.  

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