This chronology traces the major ongoing relief provided by legislation, regulatory action, and other agency guidance to assist ERISA plan participants, fiduciaries, and sponsors during the ongoing COVID-19 pandemic through August 10, 2020. Superseded agency guidance is not included in the chronology.
Terms/acronyms used:
| 2020 Date | Relief | Significance | Verrill Commentary |
| March 11 | IRS Notice 2020-15 | HDHPs may cover testing and treatment for COVID-19 before satisfaction of the deductible or with a deductible below the HDHP minimum | High-Deductible Health Plans can Cover Coronavirus Costs |
| March 13 | Declaration of National Emergency/Stafford Act Declarations of Emergency for All U.S. States, Territories, and Possessions | Stafford Act declarations permit hardship withdrawals from 401(k) and 403(b) plans for the duration of the emergency | |
| March 27 | CARES Act – Retirement Plans | – Authorizes time-limited relief for 401(k), 403(b), and governmental 457(b) plan participants directly affected by COVID-19 – Special distributions up to $100,000, with tax relief – Waives 2020 RMDs from defined contribution plans | With CARES Act, Congress Provides Retirement Plan Relief and Group Health Plan Changes |
| March 27 | CARES Act – Group Health Plans | – Mandates coverage of certain medical care to prevent or mitigate COVID-19 and of certain in vitro diagnostic services without cost-sharing or preauthorization | With CARES Act, Congress Provides Retirement Plan Relief and Group Health Plan Changes |
| April 10 | PBGC Disaster Relief Announcement | Extended deadlines for premium payments and filings due on or after April 1 to July 15 | |
| April 28 | DOL Disaster Relief Notice 2020-01 | – Relief for retirement plan fiduciaries who cannot meet certain ERISA requirements during the Outbreak Period due to COVID-19 – Good faith failures to timely furnish ERISA notices, disclosures, and other documents, if furnished as soon as administratively practicable – Guidance related to granting CARES Act distributions and loans | |
| May 4 | DOL/IRS Final Rule: Extension of Certain Timeframes for Employee Benefit Plans, Participants and Beneficiaries Affected by the COVID-19 Outbreak | Extends certain health plan time frames affecting special enrollment and COBRA coverage, as well as claims and appeal deadlines for all ERISA plans, to the end of the Outbreak Period | IRS and DOL Extend Certain Health & Welfare Benefit Plan-Related Deadlines |
| May 12 | IRS Notice 2020-29 | – Cafeteria plans may permit mid-year changes to employer-sponsored health coverage, health FSAs, and dependent care assistance programs (including dependent care FSAs) without a status change event | IRS Relaxes Rules for Cafeteria Plans and Clarifies Relief for High Deductible Health Plans |
| May 12 | IRS Notice 2020-33 | – Limit on carry-over amounts in a health FSA increased to $550 | IRS Relaxes Rules for Cafeteria Plans and Clarifies Relief for High Deductible Health Plans |
| May 27 | DOL Final Rule: Default Electronic Disclosure by Employee Pension Benefit Plans under ERISA | New alternative safe harbor for electronic delivery of required disclosures under ERISA Title I | DOL E-Disclosure Rule Recognizes our New (Digital) Reality |
| June 3 | IRS Notice 2020-42 | Temporary relief from the physical presence requirement for witnessing certain plan elections during 2020 | |
| June 19 | IRS Notice 2020-50 | Expanded relief and guidance for retirement plan distributions and loans under the CARES Act | IRS Issues New Guidance on Cares Act Retirement Plan Distributions and Loans |
| June 23 | IRS Notice 2020-51 | Guidance for waiver of 2020 RMDs under the CARES Act, including eligibility for rollover into a retirement plan or IRA if voluntarily received or received before passage of the CARES Act | |
| June 23 | IRS Notice 2020-52 | Temporary relief related to certain mid-year changes to safe harbor 401(k) or 401(m) plans that reduce or suspend safe harbor contributions | |
| July 20 | PBGC COVID-19-Related Single-Employer Plan Sponsors and Administrators Questions and Answers | Guidance for postponement of required minimum contributions under the CARES Act | |
| July 30 | IRS Coronavirus-related Relief for Retirement Plans and IRAs – Questions and Answers, Q15 | In general, participants terminated due to the COVID-19 pandemic and rehired in 2020 will not cause a partial plan termination | Employee Layoffs May Vest Retirement Plan Benefits |
| August 6 | IRS Notice 2020-61 | Guidance on the special rules relating to funding of single-employer defined benefit plans and related benefit limitations under the CARES Act |
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