COVID-19 Benefit Plan Rules & Timeframe Extensions

The Department of Labor and Internal Revenue Service issued a rule tolling certain timeframes under the Internal Revenue Code and ERISA on April 28, 2020. The extensions apply to group health and welfare plans, and retirement plans. It provides additional time to comply with certain deadlines affecting COBRA continuation coverage and to make claims for benefits and appeal denied claims. The Department of Labor also released EBSA Disaster Relief Notice 2020-1 to provide certain additional guidance and relief for employee benefit plans affected by the COVID-19 outbreak. In order to keep our brokers, customers, and participants informed, we at Infinisource will continue to provide updates here on how this rule, and any that may follow, could affect employees and employers.

Additional Resources

COBRA Flex Benefits
Participants

1. Will this extend how long I can keep COBRA (beyond the 18, 29, or 36 months)?

2. Will my grace date be extended and for how long?

3. Can I suspend my coverage without paying since I cannot use it now and then start paying when I can use it again?

4. Will my election period be extended? (Even though it currently is June or July, I have no way to pay)

5. You told me I have a grace period, why is my coverage not active while I am in the grace period?

Participants
  • May 15 FBA Participant FAQ
  • May 27 Flex Benefit FAQs
  • Q: Can I file a claim online to be reimbursed
  • A: No, claims will need to be submitted manually utilizing the Reimbursement form and attaching your itemized statements to be able to be reimbursed.
  • Q: How can I tell what claim has been denied?
  • A: You can log into your account or mobile app to view any previously denied claims. When logging in to your account, click on the “Accounts” tab and then “Claims”. You can filter your search by the claim status of “Denied” to view all denied claims.
  • Q: Does this extension change the period in which I can spend FSA funds?
  • A: Notice 2020-01 does not change the dates during which expenses must be incurred; rather, it only provides additional time to submit claims.
  • Q: Can I use my Debit Card for expenses to exhaust my available balance?
  • A: No, debit cards cannot be utilized if you are wanting to exhaust your previous plan years funds. A claim reimbursement form with itemized receipts will need to be submitted showing the expenses were incurred within the plan year that the run out period is extended.
Employers