The End Is Near: Benefit Implications from Expiring COVID-19 Emergencies

The COVID-19 emergencies are scheduled to end on May 11, 2023, signaling an end to benefit provisions employers have come to rely on in recent years. In this webinar, the Benefits Compliance team discussed how the end of these emergencies may impact your benefit plans.

Topics we covered include:

  • The end of the extension of certain timeframes (the “Outbreak Period”)
  • Certain special enrollment rights under HIPAA
  • Changes to plan documents that may be needed


  • The White House Announcement
  • The End of the COVID-19 Public Health Emergency
  • The End of the COVID-19 National Emergency

Key Takeaways

Next Steps for Employers – Documents and Notice

  • Review all plan documents and employee communications to ensure deadlines are accurately communicated
    • Any references to the Outbreak Period should be removed
  • Consider communicating the expiration of the deadline relief to plan participants
    • Not strictly required, but a really good idea!
  • Connect with COBRA Administrators to confirm COBRA notices will be updated as needed to reflect new deadlines
    • Interesting issues with stop-loss providers have popped up; ensure that COBRA is actually elected by employees that take leaves that extend beyond plan eligibility

Next Steps for Employers – Operational Steps

  • Review procedures for administering HIPAA Special Enrollment Rights, COBRA elections, and COBRA premium payments
    • Have any been incorrectly denied as untimely? If so, plan sponsor needs to consult with legal counsel
  • Some type of regulatory enforcement/checks of this issue could potentially occur. Document everything.