Important Deadline Extensions

On Jan. 30, 2023, the Biden Administration announced its intent to end the National Emergency May 11, 2023; therefore, the Outbreak Period will end July 10, 2023.

The IRS, Department of Labor, and other federal agencies released an update on health plan filing extensions due to the COVID-19 outbreak. This Rule recognizes that “participants and beneficiaries covered by group health plans, disability or other employee welfare benefit plans, and employee pension benefit plans may encounter problems in exercising their health coverage portability and continuation coverage rights, or in filing or perfecting their benefit claims” and as such offers relief through the extension of certain deadlines and notification timeframes regarding your health plan (medical, FSA, HRA) and COBRA.

  • Group health plan sponsors and administrators have more time to provide you with a COBRA election notice.
  • Certain routine actions associated with COBRA elections and continuation coverage are suspended for the duration of the COVID-19 “Outbreak Period”. The “Outbreak Period” runs on an event-by-event basis. This means, for each event, the Outbreak Period will end on the earlier of:
    • One year after it starts for that event; or
    • 60 days after the national emergency declared for the COVID-19 pandemic ends.
  • Adverse actions, such as permanent termination of your COBRA eligibility or coverage, will not be taken during the official, declared Outbreak Period


You may have additional time to take certain actions regarding your health plan and COBRA continuation coverage, including:

  • You may have additional time to take certain actions regarding your health plan and COBRA continuation coverage, including:
  • Paying the premiums for COBRA continuation coverage
  • Submitting claims for health plan benefits (Medical, FSA, HRA)
  • Disputing denials of claims for health plan benefits (deadline to file appeals of adverse benefit determinations and get external review of claim denials, if applicable)
  • Notification date for individuals to tell a health plan of a qualifying event or disability

The deadlines above are extended by disregarding the “Outbreak Period”, as defined above, when calculating the deadline.

On Thursday, March 11, 2021 President Biden signed The American Rescue Plan Act (ARPA) of 2021. The relief bill establishes a 100% COBRA premium subsidy for certain qualified beneficiaries only during the period beginning on April 1, 2021, and ending on September 30, 2021. Qualified individuals will/have been sent a letter confirming their eligibility. If you believe you are eligible and have not received a notice by May 30, 2021 please contact your Employer to confirm if you are eligible for the subsidy.


Read the Frequently Asked Questions (FAQs)** published by the IRS and DOL.

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