BREAKING: One-Year Limit on Suspended COBRA and Other Deadlines Applies On An Individual Basis

The DOL issued guidance today stating that the one-year limit on the suspension of COBRA, special enrollment, and claims deadlines during the COVID-19 outbreak period applies on an individual basis. This means those deadlines do not resume running as of March 1, 2021. Instead, each individual has up to a one-year suspension as long as the COVID-19 national emergency continues. As discussed in our prior blog post here, it was unclear whether those deadlines were to resume running as of March 1, 2021. Employers should contact their service providers to ensure they are aware of this new guidance and to issue new participant communications as needed. Notice 2021-01 is available here.