COBRA Continuation Coverage Time Periods Extended; Updated Model Notices

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**5/1/2020 - UPDATE - USDOL has published updated model COBRA notices - scroll to bottom for links**

COBRA Continuation Coverage Time Periods Extended

A new rule extends the period of time that a participant has in enrolling in coverage under a health plan, paying for COBRA continuation coverage, submitting claims for coverage and disputing denials of claims for benefits. The guidance also extends the period of time that a group health plan sponsor or administrator has to provide a COBRA election notice.  

The guidance provides that the following actions that are required to be taken during the "COVID-19 Outbreak Period" are extended until after the Outbreak Period ends, including:

  • Special health plan enrollment periods;
  • 60-day election period for COBRA continuation coverage;
  • The date for making COBRA continuation coverage premium payments;
  • The date for individuals to notify a health plan of a qualifying event or disability;
  • The date that individuals can make a claim for benefits (essentially extending the run-out period for reimbursement by health plans, health FSA or HRA plans until after the pandemic is over);
  • The dates for appeal of denied benefit plans and external review of claims denials; and
  • The date a group health plan sponsor or administrator has to provide a COBRA election notice

Guidance here: https://www.dol.gov/newsroom/releases/ebsa/ebsa20200428

FAQs here: https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/r…

EANJ's Model Notice Supplementing COBRA Documentation re: Time Extensions

UPDATED Model Notices & Other Related Documents