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During the COVID-19 national emergency, specific health plan deadlines were extended to provide individuals with more time to make decisions about their healthcare coverage. These extensions applied to deadlines for requesting special enrollment under HIPAA, electing COBRA continuation coverage and paying premiums, and submitting or appealing claims for health plan benefits. The 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.
Now that the national emergency has ended, these deadline extensions are also ending. According to the FAQs released by the Departments of Labor, Health and Human Services, and the Treasury (Departments), the outbreak period will end on July 10, 2023. Health plans will then return to their regular pre-pandemic deadlines, but any days during the outbreak period must still be disregarded to determine the specific deadline that applies to an individual.
Employers should ensure that any plan communications regarding deadlines are updated for the end of the outbreak period. To prevent employees from missing crucial deadlines, employers should clearly communicate key deadlines to impacted individuals in advance. Download the bulletin for more details.
National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.
