Compliance Q&A: End of National Emergency

After being in place for three years, the COVID-19 National Emergency was ended by legislation on April 10, 2023. At the start of the pandemic, regulators instituted a separate “Outbreak Period” running concurrently with the National Emergency that extends certain plan deadlines. The Outbreak Period was to end 60 days after the end of the national emergency, or other date announced by the agencies. The Departments of Labor and Internal Revenue Service have informally confirmed that the Outbreak Period ends on July 10, 2023. This article addresses the ways the termination of the National Emergency and Outbreak Period impacts group health plans and provides examples of revised deadlines.