COBRA Deadline Extensions Effective March 1, 2020

COBRA Deadline Extensions
May 21, 2020Summary

  1. The Departments of Labor (DOL) and Treasury, in coordination with the Department of Health and Human Services (HHS), have released a final rule to extend certain pre-established deadlines for plans and individuals, including for COBRA benefits. The full text of the rule is linked here and includes examples for the deadline extensions. This communication is focused on the impact to COBRA.
  2. The extensions are to provide relief for plans and participants during the COVID-19 National Emergency.
  3. All group health and welfare benefit plans subject to COBRA must now disregard the period from March 1, 2020 until sixty (60) days after the announced end of the National Emergency (the “Outbreak Period”) for all plan participants, beneficiaries, qualified beneficiaries, or claimants when determining deadlines for COBRA.
  4. The end date of the Outbreak Period has not been defined yet, and may be different depending on your geographical region.
  5. The COBRA deadlines extensions are:
    1. Plans must allow participants to elect COBRA up to 60 days after the end of the Outbreak Period.
    2. Plans must consider COBRA premiums as paid timely, if they are made within 30 days after the end of the Outbreak Period.
    3. Plans can delay the delivery of a COBRA election notice to participants until after the Outbreak Period, if additional time is needed to provide the notice.
  1. The duration of COBRA benefits has not changed.



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