July 10, 2023 marks the end of the COVID-19 “outbreak period,” set 60 days after the Biden administration scheduled the end of the public health emergency. As a result, several key extensions with deadlines associated with the outbreak period will expire for group health plans. The deadlines impacted include extensions for HIPAA special enrollment, COBRA coverage election and premium payments, and benefit claims and appeals.
The Departments of Labor, Health and Human Services, and the Treasury (Departments) have issued FAQs detailing how employers should apply the deadline extensions for participants enrolled in group health plans. The FAQs provide guidance on applying deadline extensions for:
- Requesting HIPAA special enrollment.
- Electing COBRA continuation coverage.
- Making COBRA premium payments.
- Filing benefit claims and appealing denied claims.
Participants who meet the criteria for a specific extension before the outbreak period ends can follow the guidance for extended deadlines compiled in our benefit plan bulletin. For more information on how the upcoming deadlines affect employer-sponsored health plans, download our bulletin.
If you are unsure about your eligibility for a specific deadline extension, please contact our Plante Moran Group Benefit Advisors.
