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Claim Filing Runout Period Extension

On Wednesday, April 29, the Employee Benefits Security Administration, Department of Labor, Internal Revenue Service, and Department of the Treasury (the “Agencies”) released a final rule (“final rule,” or “rule”) which altered and extended the timelines tied to certain benefit plans. The scope of the rule covers HIPAA, COBRA, and claim filing deadlines. A copy of the final rule can be found here.
The rule defines March 1, 2020 as the first day of what the Agencies are calling the “National Emergency” period. The Agencies are then defining what they call the “Outbreak Period” as the period of time from the first day of the National Emergency until 60 days following the date that is announced as the last day of the National Emergency period (this date has not yet been announced). The rule extends several timeframes that will affect employers, participants, and administrators.

Claims Filing and Appeals Deadline
Employee benefit plans have established timeframes within which participants can file claims previously incurred.  The rules extend the plan’s deadline to file a benefit claim and to file an appeal under the plan’s claims procedures by disregarding the Outbreak Period. The Final Rule announced by the Agencies provided extensions to deadlines tied to benefit plans.  These extensions cover HIPAA Special Enrollment, COBRA, and claims filing.  The Agencies have made it clear that the claim filing extensions do apply to any Health FSA, Limited Purpose FSA, and HRA (but not Dependent Care and Commuter Accounts).  This means that any plan year which was in its run-out period on or after March 1, 2020 will have an extended period of time to submit expenses incurred during the plan year, though the end date to submit claims will not be defined until the National Emergency is declared to be over.

Sentinel Benefits will automatically extend the runout period for any plan that we currently administer and allow additional claim filings according to these guidelines.