Among the many employee benefit deadlines extended due to the pandemic by joint action of the Department of Labor and the Internal Revenue Service are the deadlines for making a Cobra election and paying the Cobra premiums. For purposes of these deadlines, the COVID-19 “outbreak period” is disregarded. President Trump declared COVID-19 as a national emergency as of March 1, 2020, which is the beginning of the “outbreak period.” The national emergency will end when the President declares it ended. The end of the “outbreak period” is 60 days after the end of the national ...
A lot has happened since the final regulations revising the hardship distribution rules were issued on September 23, 2019 (the “Hardship Regulations”). The Secure Act was enacted in December 2019, followed by the Cares Act in March 2020, along numerous extensions of various deadlines related to employee benefit compliance. On top of that, the country is in the middle of the COVID-19 pandemic resulting in widespread business and employment disruptions. Needless to say, it would not be a surprise if the Hardship Regulations and the amendments necessary to implement them have ...