Pandemic-Related Deadline Extensions

A new 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 now extended to at least until 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 President ends it.

As of today, the pandemic National Emergency is still in effect. 

You have at least 60 days from today to take an action listed above if the original deadline for the action was on or after March 1, 2020. 

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)
  • Claim filing deadlines under Dependent Care Reimbursement Accounts

*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.