Resources

Yesterday, various government agencies released a number of new documents that impact – right now – the administration of benefit plans including:

• Final regulations (U.S. Treasury Department and the Internal Revenue Service) – extending certain deadlines including (a) HIPAA special enrollment periods – e.g., deadline for a participant to add a new baby to a health plan; (b) COBRA enrollment periods – i.e., deadline for participants to elect COBRA coverage following a qualifying event; (c) COBRA premium payment deadline; and (d) claim and appeal deadlines under benefit plans.
• EBSA Disaster Relief Notice 2020-01 (issued in coordination with Treasury, the IRS and the U.S. Department of Health and Human Services) – impacting (a) procedural requirements for retirement plan loans, distributions, plan amendments; (b) the timing of 401k deferrals and loan repayments; (c) blackout periods; (d) 5500s; and (e) M-1s.
• DOL COVID-19 FAQs for Participants and Beneficiaries – this guidance contains a series of FAQs telling plan participants of their rights during this period. Some very interesting guidance here.
• A news release on the guidance package