Update
Newsletter
By Nancy K. Campbell and Amberlee Conley
With the COVID-19 pandemic putting pressure on employers and employees alike, the Department of Labor (“DOL”), Treasury (“Treasury”), and Health and Human Services (“HHS”) (collectively, the “Departments”) continue to issue guidance intended to provide relief for plan participants and plan sponsors. However, the big winners here may be plan participants who will have longer to elect and pay for COBRA coverage, longer to elect special enrollment in group health plans, and longer to file claims and appeals for benefits. Although the guidance is well-intentioned, it places a significant burden on employers, who may already be stretched thin dealing with furloughs and layoffs.