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Getting “back to normal” as the COVID-19 pandemic has eased has not been simple for anyone. In terms of plan administration, the continued tolling of employee benefit plan deadlines, including those related to continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA), has kept plan administrators firmly planted in a “COVID-19 world,” even as many other employment practices returned to normal.
In the latest sign that pre-pandemic normalcy is slowly returning, on April 10, 2023, President Joe Biden signed legislation to end the COVID-19 national emergency effective immediately, meaning that the requirement to extend COBRA deadlines due