End of Temporary Suspension of Participant Deadlines
The end of the COVID-19 National Emergency
Summary of Material Modifications
Temporary suspensions of certain participant deadlines, such as those for electing COBRA continuation coverage, making COBRA premium payments, requesting HIPAA special enrollment after a qualifying event such as birth, adoption, or loss of other group coverage, and for filing claims and appeals, will end on July 10, 2023, which is 60 days after the end of the COVID-19 National Emergency, unless your plan specifically provides otherwise.
If the event causing a deadline period to run occurred before May 11, the deadline period will begin to run after July 10, 2023. For example, if you timely elected COBRA continuation coverage on Oct. 15, 2022, retroactive to Oct. 1, 2022, then you have 45 days from July 10 to make the initial COBRA premium payment (Aug. 24, 2023). The initial premium payment must include the total unpaid monthly premium payments for all consecutive months in which you wish to be covered, starting from October 2022 through July 2023. The premium payment for August 2023 must be paid by Aug. 30, 2023 (the last day of the 30-day grace period for the August 2023 premium payment).
If the event causing a deadline period to run occurs after May 11 but before July 10, the deadline period will begin to run starting July 10, under the established deadlines as noted in the summary plan description for your plan. For example, if you are provided a COBRA election notice on May 15, 2023, your deadline for electing COBRA coverage will be 60 days after July 10 (Sept. 8, 2023).
If a deadline period begins to run after July 10, 2023, the deadline will be the established deadlines as noted in the summary plan description for your plan. For example, if you experience a qualifying event and loss of coverage on July 12, 2023, and are provided a COBRA election notice on July 15, 2023, your deadline for electing COBRA coverage will be 60 days after July 15 (Sept. 13, 2023).
Accordingly, as of July 11, 2023, all COBRA elections, COBRA premium payments, and HIPAA special enrollment requests must be made timely, and claims and appeals should be submitted in accordance with the plan documents.
If you have any questions about how this might apply to you, including the date by which you would need to take action, please contact PacFed during normal business hours at (818) 243-0222 or email your questions to enrollment@pacfed.com.
This article repeats the content in the recently distributed Summary of Material Modifications intended to notify you of changes to your benefits due to the termination of the National Emergency and Public Health Emergency related to COVID-19 as of May 11, 2023.