President Biden has informed Congress that he plans to end the COVID-19  national emergencies on May 11, 2023. While this is a promising sign of progress, it also means that the temporary extensions introduced during the pandemic will expire. This includes COBRA coverage, FSA and HRA run-out periods, and telehealth coverage.

For those who are not familiar, COBRA stands for Consolidated Omnibus Budget Reconciliation Act, which allows employees and their dependents to continue their health insurance coverage for a limited time after leaving their job. The end of the COVID-19 national emergency will end the extensions first announced in EBSA Disaster Relief Notice 2020-01, which provided qualified beneficiaries and COBRA members with more time to elect COBRA and make premium payments. The temporary extensions were retroactive to any deadline occurring March 1, 2020 until 60 days after the COVID-19 national emergency is declared over or until one year has passed, whichever occurred first.

For FSAs and HRAs, EBSA Disaster Relief Notice 2020-01 granted a temporary extension to run-out periods, giving participants additional time to submit claims for any active plan year they are enrolled in that has a run-out period ending between March 1, 2020 and 60 days after the COVID-19 national emergency is declared over.

On the other hand, telehealth coverage has been a vital tool during the pandemic. Prior to COVID-19, only Medicare enrollees in rural areas could use Medicare to cover telehealth appointments. However, the pandemic ushered in additional flexibility, allowing all Medicare enrollees to receive coverage of telehealth costs as they would in-person appointments. The $1.7 trillion spending bill that President Biden signed into law in December 2022 included an additional two-year extension of these provisions, so Medicare telehealth coverage provisions will remain in place through 2024.

It’s important for employees to be aware of these changes and how they will affect their healthcare costs. Employers can communicate these changes to their employees through various channels, such as email newsletters, town hall meetings, or employee handbooks. Employers may also consider offering additional support and resources to help their employees navigate these changes, such as informational sessions with benefits providers or financial planning workshops. By being proactive and transparent about these changes, employers can help alleviate some of the anxiety and confusion that employees may be feeling about their healthcare costs.

So what’s next? With the national emergencies ending on May 11, 2023, it’s important for employers to communicate these changes with their employees as soon as possible.

For employers, this means reviewing any communications they have sent out related to the temporary extensions and making sure to update them to reflect the new end date. It’s also important for employers to provide resources and information to their employees to help them navigate these changes.
An important consideration is ensuring that employees will have access to the healthcare they need. This is particularly important for individuals who have been relying on telehealth appointments during the pandemic. With the end of the national emergencies, it’s possible that some insurance providers may no longer cover telehealth appointments. Employers should work with their benefits provider to understand any changes to telehealth coverage and communicate these changes to their employees.

One critical area that stands out among the rest is the emotional toll these changes may have on our workforce. The end of the national emergencies may cause anxiety and uncertainty for many individuals, particularly those who are still grappling with the effects of the pandemic. Employers may consider preparing ahead of time to offer support and resources to employees who may be struggling during this change. This could include; employee assistance programs, mental health resources, and flexible work arrangements.

In conclusion, the end of the COVID-19 national emergencies will have significant impacts on employee benefits, including COBRA, FSAs, and telehealth. Employers are encouraged to take steps to communicate these changes with their employees, provide resources and support to help employees navigate these changes, and ensure that employees have access to the healthcare they need. By taking these steps, employers can help their employees prepare for the end of the national emergencies and ensure a smooth transition to the post-pandemic world.

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