In late 2024, the Employee Benefits Security Administration (EBSA) and Treasury departments jointly issued a rule (referred to as the “Joint Notice”) extending certain compliance deadlines relating to employee benefit plans, participants, beneficiaries, qualified beneficiaries, and claimants impacted by Hurricane Helene (including Tropical Storm Helene) and Hurricane Milton.
Additionally, EBSA released EBSA Disaster Relief Notice 2024-01, which provides ERISA plans affected by the storms additional time to comply with certain notice and disclosure requirements. We are writing to share information and an action plan regarding both the Joint Notice and Disaster Relief Notice (together, “the Notices”).
Here are the highlights of the Notices:
Here are three examples of how the extensions may help impacted individuals:
1. FSA Claims Filing
*Please note that the Notices do not extend a participant’s timeframe to incur an expense, but rather to submit an expense incurred during the coverage period.
2. COBRA Election (COBRA event occurring before Relief Period)
3. COBRA Election (COBRA event occurring during Relief Period)
In the coming weeks, Sentinel will be communicating directly to FSA/HRA plan participants and COBRA beneficiaries whom our records show lived in or near an impacted area during the time of the storms mentioned in the Notices. Sentinel has built a custom form for impacted individuals to use in order to indicate they would like to take advantage of the relief. A link to the form can be found here. Please also communicate this message and form link to individuals within your organization who you know were impacted by Hurricane Helene (including Tropical Storm Helene) and Hurricane Milton.
If you have any questions regarding the Notices, please contact your Sentinel Health & Welfare and/or COBRA Account Manager.
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