Lexology March 31, 2023
Earlier this week, the Departments of Labor, Treasury, and Health and Human Services (the “Departments”) jointly issued guidance confirming that most COVID-19-related benefit coverage mandates, as well as the special tolling of benefit plan deadlines, will terminate in connection with the expected end of the Public Health Emergency (PHE) and the COVID-19 National Emergency on May 11, 2023. The guidance, which was issued in the form of FAQs, can be downloaded here.
How did we get here?
Over three years ago, the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act imposed a number of COVID-19-related coverage mandates on group health plans. For the duration of the PHE, most group health plans were...