April 30, 2020

New documents impacting benefit plan administrators released

Good morning everyone. 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

We had not planned to do the Friday call tomorrow, but given how many rules and deadlines are immediately impacted by this new guidance, we will go ahead and do a call tomorrow at 9:30 a.m. and walk through the new provisions.


Brandon Long is an experienced, AV Preeminent-rated employee benefits attorney and a member of McAfee & Taft's Employee Benefits and Executive Compensation Group.

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