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Disaster Relief, the Outbreak Period and COBRA
Starting last March when the COVID-19 pandemic began, there were updates made to COBRA to better support people who became unemployed during the pandemic. These extensions officially went into effect on March 1, 2020 and will last until the end of the “Outbreak Period,” which is the length of the pandemic plus 60 days after the COVID-19 National emergency ends.
In February 2021, the Department of Labor (DOL) released additional guidance on the Continuation of Relief for Employee Benefit Plans and Plan Participants and Beneficiaries due to the COVID-19 Outbreak — Disaster Relief Notice 2021-01. The guidance states the “Outbreak Period” extension, which commenced March 1, 2020, is limited by law to a period of 1 year from the date of the individual action, or until the end of the Outbreak Period, whichever period is shorter.
- Let's say you terminate employment which causes a loss of coverage effective 5/31/2020 and a COBRA notice was sent to you on 6/1/2020. The standard period to elect COBRA continuation is 60 days from 6/1/2020, which is 8/1/2020. The DOL guidance extends your election period to 1 year from 8/1/2020, to 8/1/2021, or 60 days from the end of the announced COVID-19 National Emergency plus 60 days, whichever occurs first.
- Let's say you previously elected COBRA and have a COBRA monthly premium due date of 7/1/2020, which has a standard grace period of 30 days (or 7/31/2020). The DOL guidance extends your grace period for paying your 7/1/2020 premium to 1 year, to 7/31/2021, or 60 days from the end of the announced COVID-19 National Emergency plus 60 days, whichever occurs first.
The updates and extensions to COBRA include the following:
- COBRA Election – The 60-day deadline to elect COBRA continuation coverage.
- COBRA Premium Payments – The 45-day (for the initial payment) and 30-day (for subsequent payments) deadlines to timely pay COBRA premiums.
- 2nd Qualifying Event and Disability Notice – The 60-day deadline to notify the Plan of events which may extend your COBRA period. (e.g., divorce or legal separation, a child ceasing to be a dependent under the term of the plan; or disability determination).
- HIPAA Special Enrollment Period Notice – The 30-day (in some instances, 60-day) deadline to request enrollment in a group health plan following a special enrollment event (i.e., birth, adoption or placement for adoption of a child, marriage, loss of other health coverage, or eligibility for a state premium assistance subsidy).
To learn more about how the COVID-19 pandemic may impact your COBRA coverage, check your qualifying event notice. You can also check out our FAQs for plan sponsors and members.
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