COVID-19 Extensions

Updated February 9, 2023

Important Notice: Extension of certain timeframes for participants and beneficiaries affected by the COVID-19 outbreak.

The enclosed document states that you must take certain actions within a specified period of time. However, due to the COVID-19 outbreak, Federal agencies announced an extension for a number of deadlines so plan participants and beneficiaries have additional time to make critical health coverage and other decisions affecting benefits during the COVID-19 outbreak. Specifically, effective March 1, 2020, participants and beneficiaries of retirement plans are provided with additional time to meet the following deadlines:

  1. The date within which individuals may file a benefit claim under the plan’s claims procedure;
  2. The date within which claimants may file an appeal of an adverse benefit determination under the plan’s claims procedure;
  3. The date within which claimants may file a request for an external review after receipt of an adverse benefit determination or final internal adverse benefit determination; and
  4. The date within which a claimant may file information to perfect a request for external review upon a finding that the request was not complete.

The Federal agencies have stated that the deadlines for the above are now subject to a deadline that ends as of the earlier of: (a) 1 year from the date the deadline would have occurred on or after March 1, 2020, absent the extension relief; or (b) 60 days after the announced end of the COVID-19 National Emergency Declaration. On the applicable date, the timeframes with periods that were extended will resume. In no case will the extension of time exceed 1 year. Please note that the Biden Administration has announced it intends to let the COVID-19 National Emergency Declaration end on May 11, 2023. If the COVID-19 National Emergency Declaration ends on May 11, 2023, as expected, the timeframes with periods that were extended will resume 60 days later (July 10, 2023).

So even though the enclosed document states that you must act within a certain period of time, the relief provided by the Federal agencies has actually extended the time period. Nonetheless, we strongly encourage you to comply with the timeframes set forth in the enclosed document so that you do not inadvertently exceed the time extension.

If you have any questions regarding the enclosed document, including your applicable deadlines, please call us at 1-800-323-5000. Additionally, if you would like to review the federal agencies’ notice regarding the extensions of time, please visit www.govinfo.gov/content/pkg/FR-2020-05-04/pdf/2020-09399.pdf.