COVID-19 national emergency is over, but COBRA obligations remain

The COVID-19 national emergency, which was originally put in place on March 13, 2020, ended on May 11, 2023. After it was declared by then-President Donald Trump, many federal agencies made changes to the procedures associated with the laws they enforce to accommodate individuals and businesses trying to navigate those uncharted waters.

For example, the U.S. Department of Labor (DOL) and the Internal Revenue Service (IRS) issued a notice extending certain time periods affecting Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) rights. Those extended time periods were described as temporary, with the duration tied to that of the national emergency. So, what happens now that the national emergency is over?