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e-Alert: COVID-19 Relief on Benefit Plans: No New Guidance at This Time

By February 26, 2021No Comments


Last year, federal agencies issued relief postponing various employee benefit plan deadlines during a defined “Outbreak Period” to help plans, participants and service providers impacted by the COVID-19 pandemic.


The Outbreak Period began on March 1, 2020, and lasts until 60 days after the announced end of the National Emergency, but by law, it cannot exceed one year. This means that the deadline relief expires on Feb. 28, 2021, in the absence of further guidance. At this time, no additional guidance has been issued.

The relief, in the form of a final rule, extends deadlines affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims and external review of certain claims. While the extension is not mandatory for non-federal governmental plans, agencies have encouraged sponsors of these plans to provide similar relief to their participants and beneficiaries. In addition, a separate Disaster Relief Notice, includes deadline extensions for notices and disclosures required under the Employee Retirement Income Security Act (ERISA).

Given the lack of agency guidance, employers and plan sponsors should begin preparing for the deadline extension relief to expire on Feb. 28, 2021.

Employers Next Steps

  • We will continue to monitor this legislation, and report in more detail on any new law enacted.
  • If you have any questions regarding this e-Alert, please contact our Benefits Team.

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