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Employee Benefits Security Administration (EBSA) Disaster Relief Notice 2021-01

On February 26, the Department of Labor (DOL) together with the Internal Revenue Service (IRS), issued Disaster Relief Notice 2021-01, which impacts COBRA participants and Reimbursement Accounts, as well as Medical and Dental TPAs.

The notice clarified that the COVID-19-related tolling periods will continue beyond the original February 28, 2021, deadline. Additionally, the order states that beginning March 1, 2021, all extensions must be measured on a person-by-person basis, which is a new clarification of the guidance provided in May 2020.

Specifically, the DOL states that the tolling periods end either:
  • One year from the date the deadline would have begun running for that individual,

    OR

     
  • 60 days from the end of the National Emergency (which is still ongoing), whichever comes first.
We are currently reviewing and evaluating this guidance. We will update you on a regular basis as we better understand the impact on our business operations.