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DOL/Treasury COVID-19 Relief Includes Long Extension of Participant Deadlines and Rule of Reasonableness for Plan Administration
Proskauer Link to more items from this source
[Guidance Overview]
May 1, 2020

"The guidance does not get into details on logistics for implementation. Plan sponsors and fiduciaries will need to grapple with issues such as: [1] When and how to communicate the extensions to affected participants and beneficiaries.... What format, and how much detail is appropriate, given that the extension period is fluid and will be short-lived? What should be done for people who are already in election periods and were previously informed of a deadline that has now been extended? [2] Whether and how past actions can be undone.... [If] an individual's COBRA coverage was previously canceled for not paying premiums, can it be reinstated? What happens if an eligible COBRA beneficiary already obtained coverage somewhere else?"

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