COVID-19 National Emergency Outbreak Period Has Ended

Based on DOL FAQ guidance and subsequent commentary, the COVID-19 National Emergency Outbreak Period ended on July 10, 2023. This means that the tolling of certain ERISA plan deadlines (e.g., COBRA elections, payments and certain notices, HIPAA special enrollments, and claims and appeals filings) will no longer be required.

Accordingly, employers should work with legal counsel, TPAs, COBRA vendors and other service providers to ensure related plan documents, procedures and systems have been updated to accommodate the Outbreak Period end and subsequent reversion to pre-pandemic election, notice and payment timelines after July 10, 2023. PPI has amended our COBRA QE Notice to reflect the applicable deadlines.

For further information, download a copy of End of COVID-19 Emergency Declarations: A Guide for Employers.