Reminder! COVID-19’s Altered Benefit Plan Deadlines

The FFCRA and CARES Act legislation extended certain guidelines applicable to plan administration actions (e.g., claims and appeals deadlines). What does this mean for employers? Plans covered by ERISA or the IRS Code must alter administrative management of plans to comply with regulatory deadline extensions.

To learn how COVID-19’s affected benefit plan regulations, including deadline extension, please visit our Geek Out! Page 

COVID-19 deadline extensions last during the “Outbreak Period.”

  • The Outbreak Period is March 1, 2020 through 60 days after the announced end of the pandemic. The longer the Outbreak Period, the more likely plans will manage a large volume of participant inquiries.

Essentially, this time period is to be “disregarded” respecting deadlines affecting:

  • COBRA;
  • HIPAA Special Enrollment;
  • claims procedures; and
  • the external review process.

Plans must consider changes to:

  • how they furnish notices;
  • how they manage claims;
  • informing applicable employees re: enrollment in the Exchange; and
  • filing of Form 5500 and the M-1.

Let’s practice…

  • If the pandemic ends August 31st 2020, the “disregarded” period ends 60 days later, or October 30th, 2020.
  • If a plan participant received medical treatment March 1, 2020 but submitted the claim relating to that treatment on August 1, 2020 (and the plan requires claims to be submitted within 365 days of receipt of medical treatment), this request would be timely.
  • Remember, the “Outbreak Period” is disregarded when calculating “timeliness,”so 365 days to submit the claim makes the last day for submission 365 days after October 30th, 2020…or October 30, 2021.

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