Issue 27

Updated June 10, 2023

After further research into the Department of Labor’s (DOL) guidance, UPMC Benefit Management Services (UPMC BMS) must modify the article in issue 27 that outlines dates associated with the end of the outbreak period.

Please see below–the modified timelines associated with the end of the COVID-19 Public Emergency and associated outbreak period pertaining to COBRA deadlines

Updated Timelines, revised based on DOL Guidance

May 11, 2023 — End Date of National Emergency

July 10, 2023 — End of outbreak period (60 days after National Emergency End Date)

July 10, 2023 — Normal COBRA grace periods resume

Aug. 9, 2023 — Last Day for qualified beneficiaries to submit past-due premiums

Aug. 24, 2023 — Last Day for 45-Day qualified beneficiaries to submit initial premium payment

On April 10,2023, President Biden signed a bill into law that officially ends the COVID-19 Public Health Emergency. The DOL issued further guidance on how the timing of this will affect COBRA timelines.

Even though the bill was signed on April 10, 2023, the DOL affirmed that the official end of the National Emergency was May 11, 2023. This means that the outbreak period will end on July 10, 2023 (60 days after the National Emergency ends).

Beginning July 10, 2023, all applicable COBRA deadlines will return to their normal time frames.

What this means for any qualified beneficiary who hasn’t made past due premium payments during the past yearlong grace period (until the end of the National Emergency). They now have until Aug. 9 to do so.

Also, any qualified beneficiary who made an election during the National Emergency, but did not pay their full premium, the 45-day grace period extends to Aug. 24.

UPMC BMS has again updated the Specific Rights Notice insert to reflect the end of the COVID-19 Public Health Emergency and wanted to share it with our clients:

View the Specific Rights Notice Insert

On April 10, 2023 President Biden signed a bill into law that officially ends the COVID-19 Public Health Emergency. Therefore, the “outbreak period” will end on June 9, 2023. Beginning June 10, 2023, all applicable COBRA deadlines will return to their normal time frames.

Since May 4, 2020, a rule was issued to extend certain deadlines occurring during the outbreak period under the Consolidated Omnibus Budget Reconciliation Act (COBRA). UPMC Benefit Management Services (UPMC BMS) modified the regulations time periods to allow for these extended time periods for both election and premium payment of which none can exceed one year.

Please know that the Department of Labor (DOL) is expected to issue further guidance. If any processes or communication must be modified as a result, UPMC BMS will communicate to our participants and clients in a timely manner.

UPMC BMS has updated the Specific Rights Notice insert to reflect the end of the COVID-19 Public Health Emergency and wanted to share it with our clients:

View the Specific Rights Notice Insert

COBRA Employer Portal Update!

You may have noticed some changes on our COBRA Employer Portal. We’ve recently undergone an employer portal refresh to improve our user experience and to streamline functionality. This refresh features a redesigned left side navigation menu as well as improved page design for some screens.

New Menu:

Our Employer Portal User Guide has been updated for your convenience, and can be accessed via the link below:

Employer Portal User Guide

If you have any questions, or would like a personalize walk-through of the updated site, feel free to contact your dedicated analyst or the UPMC BMS department at BenefitManagementServices@upmc.edu.