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Clarifying Guidance on COBRA Deadline Extension Relief


On Oct. 6, 2021, the IRS issued Notice 2021-58, which clarifies the application of certain COBRA deadline extensions for electing COBRA coverage and paying COBRA premiums under prior relief that was issued as a result of the COVID-19 outbreak.

Standard COBRA Deadlines

COBRA Election Deadline
The standard deadline for individuals to elect COBRA coverage is typically within 60 days of receiving a COBRA election notice.
 
Premium Payment Deadline
The standard deadline to make COBRA premium payments is generally at least 45 days after the 
date of the initial COBRA election, with a grace period of at least 30 days for subsequent payments.

Extended COBRA Deadlines

Emergency Relief
The Emergency Relief disregards the standard COBRA deadlines until the earlier of: (1) one year from the date individuals were first eligible for relief; or (2) the end of the Outbreak Period.
 
Notice 2021-58 
On Oct. 6, 2021, Notice 2021-58 clarified that the disregarded periods to elect COBRA coverage 
and to make COBRA premium payments generally run concurrently.

Employers should carefully review the guidance and consult benefits counsel to ensure their ongoing compliance with the Emergency Relief, as clarified by Notice 2021-58. For more information read this Compliance Bulletin for further explanation and contact HANYS Benefit Services by email or by calling (800) 388-1963.

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