FEDERAL EXTENSION OF CERTAIN TIMEFRAMES UNDER GROUP HEALTH BENEFIT PLANS

Federal Extension of Certain Timeframes Under Group Health Benefit Plans

Due to the coronavirus (COVID-19) pandemic, federal agencies have temporarily extended certain deadlines under group health benefit plans, including dental plans, disability and other plans subject to ERISA and the Internal Revenue Code, including HRAs and FSAs. The U.S. Department of Labor (DOL) and the IRS have issued a notification of relief that affects a number of deadlines, including those related to special enrollee elections, COBRA coverage, filing claims and appeals.

The COVID-19 outbreak in the United States was declared a national emergency by the President, beginning March 1, 2020. The relief notification extends certain timeframes by mandating the period starting March 1 through 60 days after the national emergency is over (known as the “outbreak period”) to not be considered in applying certain deadlines. The date for the end of the national emergency has not yet been announced.¹ However, the extension cannot exceed one year.

While the extension of time frames under the Federal Notification of Relief is not mandatory for non-Federal governmental plans, the issued guidance encourages such plan sponsors to provide relief to participants and beneficiaries similar to that specified in the Federal Notification of Relief. The guidance also encourages, but does not require, states and health insurance issuers offering coverage in connection with a group health plan to enforce and operate in a manner consistent with the relief provided in the Federal Notification of Relief. This Bulletin does not apply to health insurers offering individual health insurance coverage.

These extended timeframes are required for all ERISA groups. Non-ERISA groups are not required to comply, but the federal government recommends that groups follow these extensions.

Non-ERISA groups who do not wish to comply need to notify their Trustmark client manager before July 10, 2020. We will administer non-ERISA plans consistent with these temporarily extended deadlines unless otherwise notified.

For more information about the deadlines that have been temporarily extended and what actions are required by employers or Trustmark Health Benefits as a result, please view this chart.

You can also view a written summary of the federal guidance here.

^{1 The date of the end of the national emergency could vary for different parts of the country, if public emergencies end at different times in different states or regions.}