Smart Benefits: COVID-19 Deadline Relief for Health Plans Announced
Sam Slade, Contributor
Smart Benefits: COVID-19 Deadline Relief for Health Plans Announced
Notices and Disclosures: A DOL EBSA Disaster Relief Notice gives plan officials more time to provide notices, disclosures and other documents required by ERISA as long as they make a good faith effort to furnish them as soon as administratively practicable such as using electronic methods. This relief extends to documents due between March 1 and 60 days following the announcement of the end of the National Emergency such as:
Summary Annual Reports
Summary Plan Descriptions
Summary of Material Modifications
Extended Deadlines: A final DOL regulation, filed joined with the Department of the Treasury, provides for an extension of certain deadlines. Specifically, for the period from March 1 through 60 days after the announcement of the end of the National Emergency, the rule specifies that plans must disregard:
The special enrollment period for enrolling in a health plan after the loss of eligibility of coverage or acquiring a new dependent
The period to elect COBRA, make COBRA premium payments and notify the plan of a qualifying event or determination of disability
The time to file a benefit claim or an appeal of an adverse determination or request an external review
For guidance on the practical application of these extensions, see the examples provided in the regulation. The final rule also extends the date for a plan to provide a COBRA election notice/
Sam Slade is Managing Director, Employee Benefits, at The Hilb Group of New England, where he delivers consultative advice and services. He is an industry veteran with extensive experience in all aspects of employee benefits, including underwriting, plan design, communications, compliance, and analytics, with a particular focus on alternative funding and self-insurance. Most recently, Sam served as Vice President of the Employer Segment at BCBSRI, where he worked to help the company evolve its self-insured capabilities. Previously, he was the Employee Benefits Practice Leader for USI in Rhode Island after selling his own firm, Bluff Head Enterprises, to the company in 2011. Sam’s career started with The Travelers.