Outbreak Period Expiration Date Approaching

No new guidance has been released to extend the relief issued last year to postpone various employee benefit plan deadlines during the defined “Outbreak Period.” The Outbreak Period began on March 1, 2020, and lasts until 60 days after the announced end of the National Emergency. By law, however, it cannot exceed one year. This means that the deadline relief expires on February 28, 2021, in the absence of further guidance.

The intent of the relief, or final rule, was to help plans, participants and service providers impacted by the COVID-19 pandemic. It extended deadlines affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims and external review of certain claims. While not mandatory for non-federal governmental plans, agencies encouraged sponsors of these plans to provide similar relief to their participants and beneficiaries. In addition, a separate Disaster Relief Notice extended deadlines for notices and disclosures required under the Employee Retirement Income Security Act (ERISA).

In the absence of further guidance, these extensions will expire. For more information, please click here.


Trust the Creative Benefits Team to keep you updated should additional guidance be released. Please note this situation is evolving and included information is subject to change.