This post summarizes the health and welfare benefit plan-related deadline extensions described in IRS Notice 2020-23 issued April 9, 2020 and the DOL and Treasury Joint Notice issued April 28, 2020 (the “Joint Notice”).
IRS Notice 2020-23 expands upon previously issued guidance extending certain tax filing and payment deadlines in response to the ongoing COVID-19 National Emergency. The Notice applies to specified filing obligations and other actions that would ordinarily have a deadline on or after April 1 and before July 15, 2020. As it relates to health and welfare plans, the chart below summarizes the Notice’s limited Form 5500 filing relief and extensions of certain deadlines relating to Health Savings Accounts (HSAs) and Archer Medical Savings Accounts (MSAs).
The Joint Notice provides unprecedented extensions of certain HIPAA, COBRA, and claims procedure deadlines for participants, beneficiaries, group health and other welfare benefit plans, and plan administrators by requiring plans to disregard the “Outbreak Period” when determining the specified deadlines. The Joint Notice defines the Outbreak Period as the period from March 1, 2020 until 60 days after the announced end of the COVID-19 National Emergency (or such other date announced in future guidance). To the extent there are different Outbreak Period end dates for different parts of the country, additional guidance will be issued regarding the application of the relief provided in the Joint Notice.
Click here to access a summary in chart form of the health and welfare benefit plan-related deadline extensions described in IRS Notice 2020-23 and the Joint Notice.
Please contact a member of our Employee Benefits & Executive Compensation Group if you have any questions regarding the extended deadlines.
Verrill Attorney Annabel Rodriguez Named Top Women of Law by Massachusetts Lawyers Weekly
BOSTON, Massachusetts – Verrill attorney Annabel Rodriguez has been recognized as a Top Women of Law by Massachusetts Lawyers Weekly, and will be...What Employee Benefits Lawyers Do (and How to Make the Best Use of Us)
What do employee benefits lawyers do all day and how can clients make the best use of them? This post offers an overview of the kinds of things...Bloomberg Law Quotes Robert Keach on Expanded Access to Small Business Reorganization
Verrill attorney Bob Keach was recently featured in Bloomberg Law, discussing legislation that would raise debt limits for bankruptcy relief and...Phil Bartlett to Step Down as Chair of the Maine Public Utilities Commission
On September 15, 2026, Governor Janet Mills announced that Phil Bartlett will step down as Chair of the Maine Public Utilities Commission (PUC)...Jay McCormack and Michael Fee Co-Author AHLA Article on Skin Substitute Enforcement Trends
Verrill Partners Jay McCormack and Michael Fee co-authored an article for the American Health Law Association's Fraud and Abuse Practice Group...Verrill Welcomes Health Care & Life Sciences Attorney Elpida Velmahos
BOSTON, Massachusetts – Verrill is pleased to announce that Elpida Velmahos has joined the firm’s Health Care & Life Sciences Group as an...A New Protected Class in Maine: Holders of Final Protection Orders
In the lead-up to Domestic Violence Awareness Month in October, employers may be taking a closer look at how their policies and practices respond to...Verrill Secures SJC Victory for Boston Legacy FC in White Stadium Litigation
Verrill has secured a significant appellate victory for Boston Legacy FC in the litigation challenging the redevelopment of White Stadium in...