COVID-19 Public Health Emergency Ending

The National Emergency was ended April 10, 2023 and the Public Health Emergency is set to end May 11, 2023. This means that many of the deadlines around COBRA, HIPAA special enrollment, and other benefit deadlines will be begin to resume. Another key date to note is July 11, 2023 which is the DOL clarified duration of the Outbreak Period, which ends the earlier of (a) one year from the original deadline date; or (b) July 10, 2023.

July 11, 2023, the Outbreak Period will no longer apply. Applicable timeframes that would have otherwise been suspended will resume as stated in the Plan Document. Those suspended plan deadlines resuming July 11, 2023 will include:
• Making COBRA elections
• Making initial or monthly COBRA payments
• HIPAA special enrollments
• COBRA qualifying events

This is a good time for plan sponsors to review their plan documents, and coverage for COVID-19 related costs. Changes around out-of-network testing and treatment will be in effect May 11, 2023 at the national level. Please check for any specific state requirements. Over the counter COVID-19 testing supplies will be paid out of pocket or as permitted under the Plan’s Prescription Benefit Manager (PBM).