Yesterday, the federal agencies that have primary oversight over employer sponsored group health plans published a joint directive that impacts most of Admin America’s clients and their benefits advisors. We wanted to send you this brief update to help you better understand how the group health plans you work with are impacted by that directive.
Due to the Covid-19 pandemic, the IRS and U.S. Department of Labor’s Employee Benefits Security Administration have temporarily suspended several plan related deadlines that might otherwise jeopardize an individual’s eligibility for coverage or their ability to file claims. This will provide an extension of time for Plan Participants and Plan Sponsors to meet certain relevant deadlines. These extensions are mandatory for all impacted plans.
Of the types of deadlines listed below, those that are impacted by this new guidance are those that would have otherwise occurred on or after March 1, 2020. The impacted deadlines include:
- the time periods individuals have to enroll in group health coverage pursuant to a HIPAA special enrollment right (such as loss of group health plan coverage sponsored by another employer or a life event such as a marriage, birth of a baby or an adoption);
- the amount of time a Plan Participant has to submit claims for benefits (this provision is of particular importance to FSA and HRA plans sponsors whose 2019 claims filing deadline was March 31, 2020);
- the amount of time a Plan Participant has to file an appeal of any denial of a claim for benefits;
- the amount of time a COBRA Qualified Beneficiary has to elect COBRA continuation coverage or to make payments for the cost of continuation coverage; and
- the amount of time a Group Health Plan has to send a Qualified Beneficiary of their rights under COBRA.
The impacted deadlines are suspended until at least 60 days after the declared National Emergency related to the Covid-19 pandemic is cancelled. Admin America will be sending out additional communications in the coming weeks to impacted clients regarding our procedural responses to this guidance. In the interim, impacted FSA and HRA plan sponsors may want to notify their Plan Participants of the opportunity to re-file any claims that were denied last month because they had been submitted after a March or April deadline.
If you would like to review the actual release, it can be found online here.
If you have any immediate questions about this information, please call Admin America, Inc at 770-992-5959 or 1-800-366-2961.