On April 28, 2020, the Departments of Labor (DOL) and the Treasury (Departments) issued deadline relief to help employee benefit plans, plan participants and plan service providers impacted by the COVID-19 outbreak.

The compliance overview summarizes the participant deadline extensions affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims and external review of certain claims.

It also includes the deadline extension pursuant to the DOL’s Disaster Relief Notice 2020-01, for notices and disclosures required under the Employee Retirement Income Security Act (ERISA).

Highlights

The deadlines included in the compliance overview are extended by disregarding the period from March 1, 2020, until 60 days after the announced end of the National Emergency (or such other date announced by the Departments). This is referred to as the “Outbreak Period” and cannot exceed one year. To the extent there are different end dates for different parts of the country, additional guidance is expected.

Action Steps for Employers

Employers should continue to monitor future developments to determine when the Outbreak Period ends. The expiration date of any of the deadlines mentioned is unable to be determined until the President declares an end to the COVID-19 National Emergency or the DOL and IRS issue a notice announcing an end of the Outbreak Period.

Employers should also review the COVID-19 FAQs for Participants and Beneficiaries  provided by the DOL for additional guidance. See the link below.

Our Mission of Service

Our team at North Risk Partners will continue to monitor regulatory updates and guidance related to the COVID-19 outbreak and send you information as it becomes available. We are here to help you through this and face the risk of this virus head on, which to us is about helping you proactively control what you can control with facts and evidence-based information. Thank you for continuing to trust us with your business and doing your part to help protect our communities by controlling the spread of COVID-19.

NRP Heart

If you have questions related to this update, please contact your North Risk Partners advisor. Don’t have an advisor? No problem. We’ll help you find one.

This regulatory update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.