The pandemic may feel over in many ways, but a National Emergency is still in effect by the federal government, which has impacted a lot of employer health plan-related deadlines. When former president Trump declared COVID-19 a National Emergency, the "Outbreak Period" also began. What is the Outbreak Period? The Outbreak Period was established by the Department of Labor (DOL) and the Treasury (the "Departments"). It is a deadline extension providing plan participants, beneficiaries, and employers additional time to make critical health coverage decisions affecting benefits during COVID-19. 
The Outbreak Period started on March 1 and ends 60 days after the National Emergency. Among other healthcare benefits, a few extensions for COBRA benefits were granted when the Outbreak Period began, including:
- COBRA election period
- COBRA premium payment due date
- COBRA deadlines to notify the plan of a qualifying event or new disability
Generally, COBRA allows 60 days to elect coverage and 45 days to pay the premiums after the initial election, plus a 30-day grace period. So, from March 1, 2020, to 60 days past the end of the National Emergency, this "Outbreak Period" is discarded and does not count when determining timely COBRA elections or payments.
As of right now, the National Emergency is set to end on February 28, 2023, unless the government says otherwise. Once the time comes, employers must be prepared and ensure that all COBRA-eligible individuals granted extended timeframes due to the pandemic are correctly identified in enrollment systems so that they are made aware of the end date. Fiduciaries must keep track of all end dates, for they will not be the same for all individuals who are in the extended COBRA election or payment window.
At Medcom Benefit Solutions, our COBRA team of experts are equipped with the knowledge and experience to take care of employers' COBRA administration needs and ensure complete compliance with federal laws. We provide all federally required notices including but not limited to initial COBRA, COBRA election, open enrollment, qualifying event, short pay, conversion, extension, and termination notices.
