Expiration of Outbreak Period and Benefit Extensions

Last year, federal agencies issued relief postponing various employee benefit plan deadlines during a defined “Outbreak Period” to assist those impacted by the COVID-19 pandemic.

The Outbreak Period was defined as the period from March 1, 2020 until 60 days after the COVID-19 National Emergency ends (or such other date as the agencies announce). The relief extends deadlines affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims and external review of certain claims.

While the National Emergency has not yet attended, by law, relief of this type is limited to one year. Absent additional guidance, this means that the deadline relief will expire on Feb. 28, 2021.

Because no additional guidance has been issued at this time, employers and plan sponsors should prepare for the deadline extension relief to expire on Feb. 28, 2021.

Thank you for your attention to this matter. We will continue to keep you updated as additional information becomes available.