The COVID-19 national emergency is scheduled to end on May 11—reason to celebrate, but is your employer-sponsored group health plan ready?
At the top of the list, employers will need to communicate with plan participants.
For example, employers will need to develop a communication plan to prepare participants for the end of the “tolling period” that now ends July 10, 2023 (i.e., 60 days after the announced end date of the COVID-19 national emergency).
Specifically, participants will no longer get an extra year to take certain actions – e.g., informing plan sponsors regarding certain life events (e.g., birth of child or marriage/divorce); enrolling and paying for COBRA coverage and more.
While this is merely a return to pre-COVID rules, this will be a curtailment of rights for participants, and needs to be handled with care to make sure excess risk is not created down the road.
This will require coordination with plan vendors, including the plan(s)’ COBRA Third Party Administrator.
Communicating timely and accurately, with the help of ERISA counsel, over the next few weeks, will be key for a smooth transition.