Earlier this year, the end of the COVID-19 National Emergency was announced, which impacts certain Ohio State benefit plan deadlines that were previously extended through the National Emergency.
The National Emergency was initially set to end May 11, 2023, which defined the end of the Outbreak Period. Previously, the National Emergency allowed for extensions of several benefit-related deadlines that differed by individual and were based on the earlier of (1) one year, or (2) the end of the Outbreak Period. Although the National Emergency ended earlier than anticipated (on April 10, 2023), the Department of Labor has informally suggested that plans should continue to use the original end of the Outbreak Period, which will be July 10, 2023 (60 days after May 11, 2023). What this means for certain Ohio State benefit plans and provisions is outlined below.
The plan deadline extensions made available through the National Emergency applied to the following Ohio State benefit plans:
- Faculty and Staff Health Plan
- Dental Plan
- Vision Plan
- Disability programs
Through the National Emergency, these plans allowed for extensions of several deadlines:
- Requesting special enrollment changes to medical, dental and vision benefits due to marriage, birth, adoption, placement for adoption, divorce, loss of other group health insurance and loss of Medicaid or Children's Health Insurance Program (CHIP)
- Filing claims for medical, prescription drugs, dental, vision, long-term and short-term disability
- Appealing adverse benefit determinations for medical, prescription drugs, dental, vision, long-term and short-term disability
- Requesting an external review for medical, prescription drugs, dental, vision
- Providing notice of a COBRA qualifying event due to divorce, loss of dependent status, or determination of disability by Social Security
- Electing COBRA continuation coverage
- Paying COBRA premiums (note, claims incurred after the paid-to-date-of-coverage will be denied unless and until the applicable COBRA premiums have been paid)
With the end of the National Emergency, these deadline extensions will end at the end of the day on July 10, 2023 (the end of the Outbreak Period) and normal plan deadlines, as defined within each plan, will resume on July 11, 2023. If any further guidance is issued that may impact these dates, we will communicate as soon as possible.
See examples of extended deadline. |