Deadline Extensions and Other Relief for Employers, Plans, Participants, and Beneficiaries

Recognizing that the COVID-19 pandemic would make it difficult for employers, benefit plans, and others to comply with certain statutory requirements and deadlines, the Employee Benefits Security Administration (“EBSA”), the Department of Labor (“DOL”), and the Internal Revenue Service (“IRS”), Department of the Treasury (the “Agencies”) released a final rule (“Final Rule”) last week, formally extending certain deadlines and timeframes applicable to group health plans, welfare benefit plans, pension plans and their plan sponsors, participants and beneficiaries. The EBSA also subsequently issued Disaster Relief Notice 2020-01 (“Notice”) and a set of Frequently Asked Questions (“FAQs”) to explain the changes and extensions.

 

Specifically, the Final Rule provides extensions for claims filing deadlines and other timeframes set forth in the Employee Retirement Income Security Act (“ERISA”), Internal Revenue Code (the “Code”), Health Insurance Portability and Accountability Act (“HIPAA”), and Consolidated Omnibus Budget Reconciliation Act (“COBRA”). This relief contained in the Final Rule and guidance comes as welcome news to many employers and participants who may have been struggling to figure out how they would meet certain upcoming requirements.

 

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