Today is May 11th, the end of the COVID public health emergency and, in the benefits world, the start of a 60-day period culminating with the end of the “Outbreak Period” that extends certain benefits deadlines.
Although President Biden signed a bill on April 10, 2023 to end the COVID national emergency earlier than the original expiration date of May 11, 2023 (today), it is likely that today should still be used for purposes of determining the start of the 60-day winding down period for the special COVID extension relief for certain benefits deadlines.
This means that starting July 11, 2023, there would be a return to pre-COVID deadlines for COBRA elections, COBRA premium payments, certain COBRA notices, HIPAA special enrollment rights, and the filing of benefit claims and appeals.
Employers and plan sponsors should review their forms and internal practices to make sure that they are ready for the end of the special COVID extension relief and reflect the pre-COVID deadlines.
Additionally, employers may need to remind their employees of these deadlines to help avoid inadvertent losses of coverage or benefits (e.g., when to elect COBRA continuation coverage).