Here's a summary of the Department of Labor and the Department of Treasury guidelines on extending certain timeframes as they apply to group welfare benefit plans.
All group health plans, disability and other employee welfare benefit plans subject to ERISA must disregard the period from March 1, 2020 until sixty (60) days after the announced end of the National Emergency for all plan participants and beneficiaries in determining the following dates:
- The 30-day period (or 60-day period if applicable) to request special enrollment due a life qualifying event (e.g. loss of other coverage, marriage, birth, death, etc.).
- The 60-day election period for COBRA continuation coverage.
- The date for making COBRA premium payments.
- The date for providing a COBRA election notice.
- The date for individuals to notify the plan of a qualifying event or determination of disability.
- The date within which individuals may file a benefit claim under the plan’s claims procedure.
- The date within which claimants may file an appeal of an adverse benefit determination.
- The date within which claimants may file a request for an external review after receipt of an adverse benefit determination or final internal adverse benefit determination.
- The date within which a claimant may file information to perfect a request for external review upon a finding that the request was not complete.
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