June eNewsletter: PHE

Benefits Notification Regarding Extended Deadlines

A national emergency was declared by the federal government due to the COVID-19 pandemic.  As a part of the national emergency, employers were permitted to disregard or extend certain benefits deadlines. As a result, Texas Health did not enforce the deadlines to make certain changes to your benefits, some COBRA deadlines, and certain claims/appeals deadlines.

The national emergency has ended and the deadlines that were permitted to be disregarded or extended will begin to run on the earlier of two dates – (1) one year from the date that would have started to run or (2) July 10, 2023. Each employee’s benefit deadlines will be evaluated carefully.

If you do not qualify for the extended deadline in 2023, Texas Health Resources will begin to apply the normal deadlines as defined by the IRS and DOL guidelines. The impacted deadlines are described below:

  • Employees have 30 days to exercise HIPAA Special enrollment rights. Special enrollment rights apply to requests for enrollment in a health plan upon experiencing a loss of eligibility for group health coverage or individual health insurance coverage, or acquiring a new spouse or dependent by marriage, birth, adoption, or placement for adoption.
  • Employees have 60 days to request enrollment in a health plan upon experiencing a loss of Medicaid/ CHIP eligibility or becoming eligible for a state premium assistance subsidy under Medicaid/ CHIP.
  • Employees have 60-days to elect COBRA continuation coverage
  • Employees and qualified beneficiaries have 45 days (for the initial payment) and 30 days (for subsequent payments) to pay COBRA premiums.
  • Employees and qualified beneficiaries have 60 days to notify the plan of a COBRA-qualifying event or a new Social Security disability determination.
  • The deadline for plan sponsors and administrators to provide a COBRA election or disability extension notice (typically 30 days for the employer to provide notice to the plan administrator and 14 days for the plan administrator to provide the election notice to the qualified beneficiary).
  • The following claims and appeals deadlines will return to the pre-pandemic timeframes.
    • The deadline to file a benefit claim under an ERISA plan’s claims procedures.
    • The deadline to file an appeal of the plan’s adverse benefit determination.
    • The deadline to request an external review.
    • The deadline to submit additional information related to the external review request.

Example related to Special Enrollment Rights:

You have a baby on March 13, 2023 and would like to enroll your newborn in medical coverage at Texas Health Resources. Due to the COVID-19 deadline extensions, you were allowed to add the baby up to 30 days after the earlier of (1) one year from the date from the date of the HIPAA special enrollment event (i.e., March 13, 2024), or (2) July 10, 2023.

Other benefits changes as a result of the end of the public health emergency include an end to reimbursement of over-the-counter COVID tests effective May 11, 2023. COVID vaccines will be paid in the same manner all other vaccines are paid by the plan.