COVID-19 relief ends for employee benefit deadlines

Employee benefit deadline extensions granted in 2020 by the U.S. Department of Labor (DOL) and the IRS expired at the end of February 2021, the DOL recently confirmed. The extensions for Consolidated Omnibus Budget Reconciliation Act (COBRA) elections, Employee Retirement Income Security Act (ERISA) claim filings, and other processes were intended to continue throughout the COVID-19 "outbreak period," which remains in effect, but they ran into a one-year limit imposed by ERISA Section 518, which governs disaster-related deadline extensions.

How we got here

In late April 2020, the DOL and the IRS extended certain time frames affecting participants' rights to healthcare coverage, portability, and continuation as well as the time for plan participants to file or perfect benefit claims or appeals of denied claims. The extensions were designed to give plan participants and beneficiaries additional time to make important health coverage and other decisions affecting their benefits during the COVID-19 outbreak.

Health, disability, welfare, and pension plans were to disregard the period between March 1, 2020, and 60 days after the outbreak period when determining certain deadlines under COBRA, ERISA, and the Health Insurance Portability and Accountability Act (HIPAA).