The IRS and DOL released a joint notice April 28th that extends the period of time that a participant has to request a special enrollment under a health plan, elect and pay for COBRA, submit claims for coverage and dispute claims denied. The guidance is retro-active to March 1, 2020 and applies until 60 days after the COVID-19 National Emergency is declared over by the Federal Government.
In general terms, the guidance provides:
- Individuals up to 60 days after the National Emergency is over to elect COBRA
- Individuals up to 60 days after the National Emergency is over to notify the COBRA administrator of qualifying events
- For a lengthened time to make COBRA premium payments
- For a lengthened time individuals may request special enrollment for a HIPAA special enrollment event
There are additional rules that are currently being analyzed by the DBS team and further guidance will be provided. Of particular interest is how the ruling impacts COBRA administration, Health Care FSAs and Health Reimbursement Arrangements.