Lexology April 6, 2023
With the COVID-19 Public Health Emergency (PHE) set to end on May 11, 2023, federal agencies have published FAQs explaining how the end of the PHE will affect previously extended deadlines relating to COBRA, HIPAA special enrollment, and claims and appeals under group health plans. This article provides (i) a recap of the deadlines, (ii) rules of thumb for determining the deadlines, and (iii) tables more specifically addressing some of the most common deadlines that arise. Plan administrators should review plan operations now and prepare to administer these shifting deadlines correctly to avert potential penalties and minimize avoidable claims exposure.
Deadlines Subject to Extensions
In prior articles, we described the original actions taken by federal agencies to extend these deadlines...