Recent Guidance on Extension of Certain Timeframes for Employee Benefit Plans
Date Recorded: May 4, 2020
Cost: Free webinar
On Wednesday, April 29, 2020, the DOL and the IRS jointly issued guidance (“Guidance”) that will have significant implications for group health plan sponsors and their administrators. The Guidance directs group health plans and group health insurers to disregard the period between March 1, 2020, and 60 days after the announced end of the COVID-19 National Emergency (the “Relief Period”) when calculating the certain plan related time periods described below:
30-day or 60 day time period to request special enrollment in a group health plan (e.g. when a spouse loses eligibility for coverage under another group health plan due to a termination of employment, layoff or furlough);
The qualified beneficiary’s 60-day period to elect COBRA;
The plan administrator’s 14 day period for sending COBRA election notices;
The 45 day period (initial premium) and 30 day (subsequent premiums) grace period for qualified beneficiary’s to make COBRA premium payments;
The qualified beneficiary’s 60 day period to notify the plan administrator of a qualifying event (or second qualifying event) or a qualified beneficiary’s determination of disability;
The time period under the plan for the claimant to file a benefit claim (including the run out period for Health FSAs) and the 180 day period to file an appeal;
A claimant’s 4 month period to request external review or perfect an external review.
The net result is that the application of the Guidance to these time periods is as follows: (i) any of the following time periods that began before March 1 but did not expire prior to March 1 are tolled until the end of the Relief Period, and (ii) the start date of any of the following time periods that would otherwise begin on or after March 1 is postponed until the end of the Relief Period. More importantly, we don’t really know when the National Emergency will end; therefore, we don’t really know when the Relief Period will end. This could significantly, and adversely impact health plan administration.
In this webinar, we will drill down on the practical application of the new guidance so that you know what changes you need to make to your systems and processes in order to comply with the new rules.
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