
Several key deadlines for employer-sponsored health plans were extended during an “outbreak period” associated with the COVID-19 national emergency. Now that the COVID-19 national emergency has ended, these deadline extensions are also coming to an end. According to FAQs issued by the Departments of Labor, Health and Human Services, and the Treasury (Departments), the outbreak period will end on July 10, 2023.
During the outbreak period, certain health plan deadlines were extended to give individuals more time to make decisions about their health coverage. The extensions applied to deadlines for:
- Requesting special enrollment under HIPAA;
- Electing COBRA continuation coverage and paying COBRA premiums; and
- Submitting claims for health plan benefits and appealing denied claims.
These deadline extensions end when the outbreak period is over or, if earlier, after an individual has been eligible for a specific deadline extension for one year.
Action Steps
Once the outbreak period ends on July 10, 2023, health plans can go back to their normal pre-pandemic deadlines. However, any days during the outbreak period must still be disregarded to determine the deadline that applies to a specific individual. In addition, employers should ensure that any plan communications regarding deadlines are updated for the end of the outbreak period. To help prevent employees from missing crucial deadlines, employers should clearly communicate key deadlines to impacted individuals in advance.
Highlights
- During the COVID-19 pandemic, certain health plan deadlines were extended by disregarding an “outbreak period.”
- The outbreak period will end on July 10, 2023.
- Once the outbreak period ends, health plans can go back to their normal pre-pandemic deadlines.
- Employers should ensure that any descriptions of plan deadlines are updated to reflect this change.
FAQ Guidance
- The Departments issued FAQs to address how certain health plan requirements related to the COVID-19 pandemic will change when the emergency periods end.
- The FAQs include examples to explain how the deadline extensions should be applied as the outbreak period comes to an end.
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