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Additional Guidance Released for Extended COBRA

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This update applies to Non-Federal Government Entities Only.


Since our communication to you on May 4th, 2020 (available here), we have received further guidance from our Benefit Compliance Team that non-Federal government plans are encouraged, but not required, to comply with these extended deadlines. The Insurance Bulletin that drew attention to this relaxation of enforcement can be found at:


As compliance with the original guidance is not mandatory, BCC will begin following the standard COBRA guidelines which permit termination of coverage due to non-payment of premiums. We will also enforce deadlines to elect coverage and send notice of qualifying events and disability.


If you wish to comply with the DOL and IRS’s original guidance of extended time frames, please contact our Enterprise Service Team at