Outbreak Period Ends

The National Emergency in response to COVID-19 that began on March 20, 2020, ended on May 11, 2023. The Outbreak Period ended July 10, 2023, 60-days after the end of the National Emergency.   
With the Outbreak Period ending today, the extension of deadlines that were permitted under the Notice of Extension of Certain Timeframes for Employee Benefit Plans, Participants and Beneficiaries Affected by the COVID-19 Outbreak(the Joint Notice) will come to an end. This means that normal deadlines will begin to apply.  
The deadlines that were formerly extended but that will now resume include the following.

  • HIPAA special enrollment periods
  • 60-day election period for COBRA continuation coverage
  • Date for making COBRA continuation coverage premium payments
  • Date for individuals to notify a health plan of a qualifying event or determination of disability
  • Date that individuals can make a claim for benefits under the plan's claims procedures (extending the runout period for reimbursement by health plans, health FSAs, or HRA plans until after the pandemic has subsided)
  • Date for individuals to perfect an incomplete claim
  • Dates for appealing denied benefits and for external review of claims denials
  • Date that a group health plan sponsor or administrator must provide a COBRA election notice