Updated End Date for COVID-19 National Emergency and Impact on Deadline Extension for ERISA-Governed Plans

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4.13.23

This client advisory follows up on our recent advisory regarding the joint agency FAQS on the impact of the end of the COVID-19 on certain benefits related relief and extensions here.

This week, President Biden signed a bill ending the COVID-19 national emergency effective as of April 10, 2023, rather than the assumed end date of May 11, 2023 indicated in our recent advisory.  The COVID-19 public health emergency is still expected to end May 11, 2023.

As a result of the change to the COVID-19 national emergency end date, the "Outbreak Period" used in applying the benefits-related extensions, discussed in "Extension of Timeframes for ERISA-Governed Employee Benefit Plans" of our recent advisory, will be June 9, 2023, rather than July 10, 2023.   

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