COBRA extension deadline considerations for multiemployer plan sponsors

Recently, the U.S. Departments of Labor and Treasury and the Internal Revenue Service jointly issued guidance extending certain deadlines related to COBRA continuation coverage.

The extension of deadlines described are based on the “Outbreak Period,” which is defined as the period from March 1, 2020, until 60 days after the federal government declares the end of the National Emergency, or other such date announced by the agencies. The guidance issued by the agencies also includes suspension of time limits related to HIPAA special enrollment rights and filing benefit claims, appeals, and external reviews during the Outbreak Period. These time limits do not begin to run out until the end of the Outbreak Period.

In this Multiemployer Alert, Milliman’s Sean Silva and Eric Walters discuss the COBRA election period, COBRA payment deadlines, and the potential impact on plan sponsors.

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