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The US Department of Health and Human Services (HHS) has once again the declaration of a public health emergency due to COVID-19 another 90 days.  Since initially declared in January a year ago, it has been extended for successive 90 day periods in April, July, and October 2020, and is now extended to last through April 21, 2021.

The public health emergency dictates how long health plans must continue to pay for COVID-19 testing and vaccines without cost sharing, whether secured in- or out-of-network.

This is separate from the President’s declaration of a national emergency in March 2020, which dictates how long health plans must honor an Outbreak Period extension for special enrollment rights under HIPAA, timely claims and appeals under ERISA, and all COBRA deadlines.  The national emergency also remains in effect.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.