2024 Pay or Play Affordability Percentage

COVID-19 National Emergency Ended

President Biden signed a resolution on April 10, 2023, effectively ending the COVID-19 national emergency. The national emergency and public health emergency (PHE) were previously scheduled to end on May 11, 2023, but the bipartisan legislation ended the former earlier than expected, on April 10.

Effects of terminating COVID-19 national emergency

With the end of the national emergency, the outbreak period, which extended various employee benefit plan deadlines, will end on June 9, 2023, reverting plans to their nonextended deadlines. These deadlines include:

  • HIPAA time frames – the time period to request special enrollment.
  • COBRA time frames – window for qualified beneficiaries to elect COBRA coverage and make premium payments. The date for individuals to notify the plan of a qualifying life event or disability determination is also affected.
  • Claims procedure time frames – timeline in which to file a benefit claim or appeal of an adverse benefit determination under the specified claims procedure.
  • External review process time frames – window in which data claimants can request an external review due to an adverse or final internal adverse benefit determination.

Public health emergency still effective

While the national emergency has ended, the PHE end date has not changed from May 11, 2023. The end of the PHE will affect the coverage of COVID-19 tests and services, but plans will still be required to cover recommended preventive services, like COVID-19 vaccines, without cost-sharing if obtained in-network. As the deadline approaches, health insurance carriers will begin releasing more information depicting how coverage will change once the PHE is terminated.

Federal agencies require plan sponsors and employers to clearly communicate coverage changes, due to the end of the emergency periods, to participants and beneficiaries before they take effect.


As more information is made available, Creative Benefits, Inc. will release updates. If you have any questions, please contact your dedicated Creative Benefits team member.