The federal rule issued on May 4, 2020, entitled Extension of Certain Timeframes for Employee Benefit Plans, Participants and Beneficiaries Affected by the COVID-19 Outbreak, provides participants in certain employee benefit plans* additional time to:
- Elect COBRA coverage
- Make COBRA premium payments
- Notify the Plan of second qualifying events under COBRA
- File medical, dental, vision, Medical Care Reimbursement Account (MCRA )(aka health FSA), and disability claims for covered benefits/eligible expenses
- Appeal denials of medical, dental, MCRA and disability claims
- Make a Special Enrollment Request under HIPAA rules for medical or dental coverage
The deadlines for taking any of the actions described above that would ordinarily have been due on or after March 1, 2020, are extended to the earlier of the following dates:
- One year from original due date shown in your Explanation of Benefits, COBRA Election Notice or response to your request for an appeal, or
- At least 60 days after the end of the pandemic National Emergency, (the pandemic National Emergency was declared by the President to begin on March 1, 2020, and will continue until the current President ends it).
This message will be updated when the pandemic National Emergency has ended.
What’s not affected
The new rule does not apply to the deadlines related to:
- Active employees initially enrolling in a plan
- Change in status events, except a change in status that also qualifies under the HIPAA Special Enrollment rules (see your Plan Document for information about HIPAA Special Enrollment)
*Plans sponsored by government entities or churches are not required to extend these deadlines. If you are covered by a government or church-sponsored plan, please call the member service number on your Plan Identification Card to find out if the deadline extension applies to your plan.
*Medical, dental, vision and Medical Care Reimbursement Account plans only