Additional COVID-19 Extensions = Greater Administrative Headaches for Plan Sponsors
May 5, 2020
Authored by: Serena Yee and Steve Evans
As any employer is keenly aware, the administration of an employee benefit plan (especially a group health plan) involves a number of different deadlines imposed under the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code (Code). Amidst concerns that the current COVID-19 pandemic may cause individuals to lose benefits due to the failure to meet certain pre-established deadlines and in recognition of the challenges group health plans may face in complying with certain notice obligations, the Department of Labor and Internal Revenue Service (collectively, the “Agencies”) jointly published notice in the Federal Register of a significant extension in application of the following statutorily prescribed deadlines:
Special Enrollment Periods
- 30-day deadline to request enrollment in the event of a loss of eligibility for other health coverage or the acquisition of a new dependent due to marriage, birth, adoption or placement for adoption
- 60-day deadline to request enrollment in the event of either a loss of eligibility for coverage under Medicaid or a state children’s health insurance coverage (CHIP) or gaining eligibility for premium assistance through Medicaid or CHIP.
COBRA Continuation Coverage
- 30-day period for employer to notify plan administrator of certain COBRA qualifying events
- 14-day period for plan administrator to issue COBRA Election Notice to qualified beneficiary
- 60-day period for qualified beneficiary to elect COBRA continuation coverage
- 45-day period for qualified beneficiary to submit initial COBRA premium payment
- 30-day period for qualified beneficiary to submit subsequent COBRA premium payments
- Qualified beneficiary’s