"Plan sponsors might soon see an influx in requests for mid-year enrollment due to the loss of Medicaid coverage.... Plans should ensure their claims administrator follows plan terms and removes any time extensions applicable to claims and appeals adopted due to the [national emergency (NE)].... If the plan sponsor did take advantage of the safe harbor for employer actions, recognize that applicable notice deadlines going forward must adhere to pre-NE COBRA and ERISA rules.... Plans sponsors have the opportunity (except those with HDHPs ... ) to reevaluate whether they wish to continue offering free or low-cost COVID-19 testing."

MORE >>