Among the many employee benefit deadlines extended due to the
pandemic by joint action of the Department of Labor and the
Internal Revenue Service are the deadlines for making a Cobra
election and paying the Cobra premiums. For purposes of these
deadlines, the COVID-19 "outbreak period" is
disregarded. President Trump declared COVID-19 as a national
emergency as of March 1, 2020, which is the beginning of the
"outbreak period." The national emergency will end
when the President declares it ended. The end of the
"outbreak period" is 60 days after the end of the
national emergency (unless the DOL/IRS provide a different deadline
for these extensions).
Before addressing how the deadlines are affected by the
extension, keep in mind the standard Cobra deadlines:
