Deadline relief continues for health plans and participants 

To provide relief during the COVID-19 National Emergency that began March 1, 2020, the departments of Labor (DOL) and Treasury released guidance (the joint notice) in May 2020 extending the deadlines for a number of employee benefit plan requirements. The extensions aim to ensure individuals do not miss key deadlines during the pandemic that could cause, for example, lapse of group health plan coverage or denial of a valid benefits claim.

Separate DOL guidance (Notice 2020-01) also extended certain deadlines to help employers and other plan sponsors, fiduciaries, and service providers meet some — but not all — of their ERISA obligations during the pandemic. EBSA Disaster Relief Notice 2021-01 clarifies and explains the 2020 relief for health and welfare plans. The latest updates to this GRIST reflect IRS Notice 2021-58, which clarifies how the extended deadlines apply to COBRA elections and payment of COBRA premiums. A separate GRIST reviews the deadline relief for retirement plans.

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