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What Does the End of the COVID-19 Public Health Emergency Mean for Your Benefit Plans? 

February 17, 2023

Recently, the federal government announced that it would declare an end to the COVID-19 public health emergency on May 11, 2023. This change will affect coverage for COVID-19-related services and various procedural deadlines. 

COVID-19 vaccines  

COVID-19 vaccines have been added to the Affordable Care Act’s list of preventive care benefits. As a result, members with the following Blue Cross Blue Shield of Michigan and Blue Care Network plans will continue to receive 100% coverage in-network for COVID-19 vaccine administration after the end of the public health emergency:   

• Employer plans subject to ACA requirements  

• Medicare Advantage plans  

• Individual business plans   

The above plans will also cover the cost of the COVID-19 vaccine product in network after current government supplies are depleted. Out-of-network coverage will be subject to group-specific benefits.   We’re working with employer plans not subject to ACA requirements to make decisions about adding or enhancing their own benefits for COVID-19 vaccines.   

COVID-19 testing and treatment  

Blue Cross and BCN are working to determine how the end of the public health emergency affects COVID-19 testing and treatment for our members and customers. BCBSM/BCN will provide more information in the upcoming webinar for groups that they are hosting on March 2nd. Details available here.    

Return to Status Quo 

Employers should prepare their benefit plans for a return to the status quo with respect to plan deadlines. As background, in response to the national emergency originally declared in early March of 2020, the federal agencies extended certain timeframes that applied to benefit plans during the COVID-19 presidential national emergency.  

The extensions include the delay or suspension of certain COBRA, HIPAA special enrollment, and claims and appeals filing procedure deadlines. These deadlines were paused during a period called the “Outbreak Period” — beginning on March 1, 2020, which was the start of the presidential national emergency, and ending 60 days after the end of the presidential national emergency is announced. For example, if an employee was provided a COBRA election notice on February 1, 2023, the employee would normally have 60 days to return their COBRA election form. However, due to the presidential national emergency, the employee would not need to return the COBRA election form until 60 days after the end of the presidential national emergency. 

Now, the “Outbreak Period” is set to expire on July 10, 2023, which is 60 days after May 11, 2023, the intended end of the presidential national emergency. At that time, the following benefit plan deadlines will return to normal and will no longer be extended: 

HIPAA Special Enrollment: 

  • The 30-day period (or 60-day period if applicable) to request special enrollment for a new dependent through marriage, birth, adoption or placement for adoption; loss of other coverage; becoming eligible for a state Medicaid or premium assistance subsidy (CHIPRA). 

Example: An employer’s health plan provides that an employee must request enrollment of a newborn child within 31 days of the birth. An employee has a new baby on April 1, 2023. The employee must request to enroll the baby by July 10, 2023. 


  • The 60-day election period for continuation of coverage. 
  • The date for making COBRA premium payments. 
  • The date for individuals to notify the plan of a qualifying event or determination of disability. 

Example: An employee is enrolled in COBRA, but does not make a payment due by April 30, 2023. The employee must make the payment by July 10, 2023, in order for COBRA coverage associated with the April 30, 2023, payment to be reinstated. 

Claims and Appeals (including retirement plan claims and appeals, and reimbursement claims under health flexible spending accounts): 

  • The date within which individuals may file a benefit claim. 
  • The date within which claimants may file an appeal. 
  • The date within which claimants may file a request for external review. 
  • The date within which claimants may file information to perfect a request for external review. 

Example: An employee did not submit claims for reimbursement under their employer’s health FSA by the March 15, 2023, deadline. The employee has until July 10, 2023, to submit the claims for reimbursement. 

Employers should work with their benefit plan service providers (e.g., enrollment administrators, COBRA administrators, health plan insurers/TPAs) to address any administrative changes that may be needed to accommodate the end of the Outbreak Period. Employers should also issue a notice to employees that the Outbreak Period is intended to expire in July, so that employees who have taken advantage of the Outbreak Period deadline extensions can prepare to submit necessary documents or forms. 

SBAM’s Member Care Team is here to support you! If you’re enrolled in SBAM-sponsored BCBSM/BCN or COBRA administration, you can reach out to us with questions at (877) 949-7226 or  

Sources: Blue Cross Blue Shield of Michigan and Warner Norcross & Judd 

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