The COVID-19 “Outbreak Period” was anticipated to end 60 days after the end of emergency period. During that period, certain deadlines for the events outlined below were paused. The regular deadline timing for these events will resume starting on July 10, 2023. As these extended deadlines are applied on a case-by-case basis and if you have a question about the appropriate deadline for a particular claim or appeal, please contact the carrier (Aetna, Cigna, Express Scripts) directly for further assistance.
- Enrolling in a health plan upon a special enrollment event
- Electing COBRA continuation of coverage
- Making COBRA premium payments
- Notifying the plan of a COBRA qualifying event or determination of disability
- Filing an initial benefit claim or appeal of an adverse benefit determination for disability, retirement and other plans
- Filing an initial benefit claim, appeal of an adverse benefit determination and external review of certain claims for health plans
For example, assume that you experienced a COBRA qualifying event on March 1, 2023. Ordinarily, you would have a 60-day election period, or until April 30, 2023, to elect COBRA continuation coverage. However, the “outbreak period” pauses these deadlines until July 10, 2023. As a result, the 60-day election period will not start to run until July 11, 2023, and you will have 60 days from July 11, 2023, or until September 8, 2023, to elect COBRA continuation coverage. You are still responsible for premium payments for the entirety of the period that you are covered (beginning with your qualifying event), even if your election deadline was adjusted due to the emergency period.