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On October 6, 2021 the IRS released new guidance, IRS Notice 2021-58, that further explained the application of extensions for the election of COBRA and payment of COBRA as set forth on May 4, 2020 in response to the COVID-19 National Emergency.

The guidance clarified that the disregarded period for a participant to elect COBRA continuation coverage and the disregarded period for the participant to make initial and subsequent COBRA premium payments generally run concurrently. Participants have until (1) up to one year and 60 days after the participant’s receipt of the COBRA election notice or (2) 60 days after the end of the Outbreak Period , whichever is earlier, to make the COBRA election and initial payment.  

On February 10, 2023, President Biden announced that he plans to end the COVID-19 National Emergency on May 11, 2023.  

The Departments of Labor (DOL), Health and Human Services, and the Treasury issued guidance on March 29, 2023, providing awareness and clarity to changes that will accompany the end of the National Emergency and how those changes will impact the COBRA grace period extensions and the outbreak period.  

Recently the US Senate passed a bill that, if signed by President Biden, will end the National Emergency immediately. 

Extensions and the Outbreak Period
The March 29, 2023 guidance clarifies that with the anticipated end of the National Emergency on May 11, 2023, the Outbreak Period will end July 10, 2023 (60-days after the anticipated end of the National Emergency).  The extensions under the emergency relief for timeframes that began during the National Emergency no longer apply.  As clarified in 2021, the disregarded period was permitted to a period of 1 year from the first date of eligibility for the relief or the announced end of the outbreak period, whichever occurred first.  

Further clarification in the March 29, 2023 guidance states that individuals, in some circumstances, will still be permitted a minimum timeframe to complete elections, initial payments, and subsequent payments.  See examples below, assuming the National Emergency end date is May 11, 2023.

COBRA Election Outbreak Period:

  • COBRA SRN Date: 5/1/2023
  • “Normal” time period for making election: 60 days
  • Outbreak End (7/10/2023) + 60 days = 9/8/2023

COBRA Election Outbreak Period, After the end of the National Emergency:

  • COBRA SRN DATE: 5/12/2023
  • “Normal” time period for making election: 60 days
  • Outbreak End (7/10/2023) = 60 days = 9/8/2023

COBRA Election – 1 year

  • COBRA SRN Date: 5/30/2022
  • “Normal” Elect by Date (60 days): 7/29/2022
  • 7/29/2022 + 365 days = 7/29/2023

Initial Payment Outbreak Period:

  • COBRA SRN Date: 10/01/2022
  • Participant Elected: 10/15/2022
  • “Normal” time period for making the initial payment: 45 days
  • Outbreak End (7/10/2023) + 45 days = 8/24/2023

Subsequent Payment Outbreak Period:

  • First Day of Coverage: 7/01/2022
  • Participant Paid Thru 9/30/2022, takes the extension
  • Premium Month Owed: 10/1/2022
  • “Normal” time period for making subsequent payments: 30 days
  • Outbreak End (7/10/2023) + 30 days = 8/09/2023
  • Required Premiums: October 2022 – July 2023
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