May 19, 2023
Circular Letter: 600-025-23
Topic: Health Benefits

To: All CalPERS Health Benefits Officers and Assistant Health Benefits Officers

Purpose

This Circular Letter supersedes Circular Letter 600-039-20 (PDF). The purpose of this Circular Letter is to inform all health benefits officers (HBOs) and assistant HBOs of the Department of Labor (DOL) and Internal Revenue Service (IRS) COVID-19 Relief Rule period expiration.

Background

As a result of COVID-19, the president of the United States formally declared a national health emergency on March 13, 2020, under Proclamation 9994. The IRS and DOL initially published a Notification of Relief entitled Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak on April 28, 2020 (Notice).

On July 31, 2020, CalPERS notified all HBOs and assistant HBOs of the timeframes and special enrollment periods under this ruling, via Circular Letter 600-039-20. The relief duration began on March 1, 2020, and was set to expire sixty (60) days after the announced end of the national health emergency.

Relief Expiration

On April 10, 2023, the president formally signed a House of Representatives bill immediately ending the COVID-19 national emergency. As a result, the extension of timeframes will end on June 9, 2023. Effective June 10, 2023, timeframes will revert to the applicable timelines associated with each qualifying event for employees to:

• Enroll due to loss of coverage, includes employees and their dependents who lose coverage under a state Children's Health Insurance Program (CHIP) or Medicaid or who are eligible to receive premium assistance under those programs
• Add dependents due to marriage, birth, adoption, or placement for adoption
• Enroll in Consolidated Omnibus Budget Reconciliation Act (COBRA)

COBRA Premium Payments

The COVID-19 Relief Rule stipulated application of the relief period to the timely collection of COBRA premiums, which prevented individual health cancellations due to late or non-payment until 90 days after the national emergency is declared over. As a result, any COBRA premium payments that were deferred during the COVID-19 national emergency must be paid in full no later than July 9, 2023.

Questions

We are committed to assisting you in conducting business with the CalPERS Health Benefits Program. If you have questions, call the CalPERS Customer Contact Center at 888 CalPERS (or 888-225-7377888-225-7377).

 

Yesenia Croft, Chief
Health Account Management Division