Important Update: Based on informal comments from the U.S. Department of Labor, it appears that the tolling of benefit plan deadlines will end on July 10, 2023, as described in our earlier blog on this subject, notwithstanding the legislation that was signed on Monday ending the COVID-19 National Emergency on April 10th
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It’s Over: DOL, Treasury, and HHS Confirm End of (Most) COVID-19 Rules for Health Plans
Update: On April 10, 2023, President Biden signed into law legislation ending the COVID-19 National Emergency prior to the previously announced May 11, 2023 date. See our blog on this new development here. The legislation does not impact the end of the COVID-19 Public Health Emergency.
Earlier this week, the Departments of Labor, Treasury,…
The Long-Awaited End of the Tolling of Plan Deadlines due to COVID-19
By Roberta Chevlowe & Tanusha Yarlagadda on
The Biden Administration recently announced that the COVID-19 National Emergency will end on May 11, 2023. This means that the requirement to extend various benefit plan deadlines due to the COVID-19 pandemic will end as well.
By way of brief background, early during the pandemic, the U.S. Departments of Labor and Treasury adopted relief pursuant…
COBRA Election and Payment Periods: Does One Year of “Tolling” Really Mean One Year?
By Paul M. Hamburger & Roberta Chevlowe on
Remember the DOL/Treasury relief that tolled the COBRA election and payment deadlines for up to one year due to the COVID-19 pandemic (referred to below as “Tolling Relief”)? If you have been wondering whether, under that relief, a qualified beneficiary may wait one year to elect COBRA and then wait another year to make their…
ERISA Participant’s Supplemental Submission Doesn’t Restart Exhaustion Clock
By Madeline Chimento Rea on
A federal district court in New Jersey held that supplemental documentation submitted by a participant in connection with the claims review process did not restart the clock for a claims administrator to decide the participant’s appeal. Plaintiff Tracee Lewis-Burroughs timely appealed Prudential Insurance Company of America’s decision to stop paying her long-term disability benefits.