Disaster Relief Overview
Certain FSA, HRA, COBRA, and HIPAA Special Enrollments deadlines have been extended for individuals affected by Hurricane Helene, Tropical Storm Helene, and Hurricane Milton.
If you have been affected by one of these federally declared disasters, you may qualify for extended deadlines for your Flexible Spending Account (FSA), Health Reimbursement Arrangement (HRA), and COBRA coverage(s).
Deadline Extensions
Disaster Relief Notice 2024-01 mandates the extension of the following deadlines:
- COBRA 60-day election period
- COBRA premium payments
- HIPAA special enrollment 60-day election period
- FSA/HRA claims submission deadline
- FSA/HRA claims appeal deadline
Under the extension, the regular deadlines are paused until the end of the “Relief Period” designated as May 1, 2025.
Relief Period Eligibility
The relief applies to individuals in designated disaster areas in Florida, Georgia, North Carolina, South Carolina, Virginia, and Tennessee.
If you resided, lived, or worked in a designated disaster area at the time of the disaster, or if your benefit coverage was under a plan directly affected by the disasters, you are eligible for these extensions.
The relief period ends on May 1, 2025 for all affected individuals. The start date of the relief period varies depending on your location and which disaster impacted you. The start of the Relief Period aligns with the beginning of the “incident period” established by the Federal Emergency Management Agency (FEMA).
What is the process of activating deadline extensions?
Action is required to activate these deadline extensions. If you believe you are eligible for a deadline extension and have an FSA, HRA, or COBRA account with Vita, you must contact the Vita Concierge team at help@vitamail.com or (650) 966-1492 to request an extension. Vita will confirm your eligibility and which extended deadline(s) apply to you. If no action is taken, you will be subject to the standard deadlines.
FSA/HRA Deadline Extension
If you are eligible and notify the Vita Concierge team, your claims submission deadline will be extended to the end of the Relief Period + 90 days. For calendar year plans, this means the normal March 31st deadline for the 2024 Plan Year will be extended to July 30, 2025.
The relief does not provide any extensions for the dates when claims must be incurred under an FSA or HRA plan.
COBRA Beneficiary Assistance
The Vita Concierge team will assist you if your election window has closed or if your coverage was terminated due to late payment under the “regular” rules. Election period/payment extensions and coverage reinstatements will be considered on an individual basis once you identify yourself as eligible by notifying the Vita Concierge team.
Examples of Deadline Extensions
For reference in understanding how the deadline extensions will apply to individuals in various situations, the following examples may help:
| FSA/HRA Claims Submission Run Out | |
| Plan Year end | 12/31/2024 |
| Normal run out period end (90 days) | 3/31/2025 |
| Relief period end (5/1/2025) + 90 days | 7/30/2025 |
| Final claims filing date | 7/30/2025 |
| FSA/HRA Claims Appeal | |
| Claim denial date | 12/1/2024 |
| Normal appeal period (180 days) | 5/30/2025 |
| Relief Period End (5/1/2025) + 90 days | 10/28/2025 |
| Final claims appeal date | 10/28/2025 |
| COBRA Election before Relief Period | |
| Incident period start date | 10/5/2024 |
| Qualifying Event and loss of coverage date | 10/01/2024 |
| COBRA Qualified Event Notice mailing date | 10/01/2024 |
| “Normal” time period for making election: | 60 days |
| Relief period end (5/1/2025) + 60 days - 5 days that had passed before the incident start period (10/5/2024) | 6/25/2025 |
| COBRA Election during Relief Period | |
| Qualifying Event and loss of coverage date | 12/01/2024 |
| COBRA Qualified Event Notice mailing date | 12/10/2024 |
| “Normal” time period for making election | 60 days |
| Relief period end (5/1/2025) + 60 days | 6/30/2025 |
| COBRA Election after Relief Period | |
| Qualifying Event and loss of coverage date | 5/15/2025 |
| COBRA Qualified Event Notice mailing date | 5/20/2025 |
| “Normal” elect-by Date (60 days) | 7/19/2025 |
| Initial Payment before Relief Period | |
| Qualifying Event date | 10/1/2024 |
| COBRA Qualified Event Notice mailing date | 10/1/2024 |
| “Normal” time period for making initial payment | 45 days |
| Participant elected | 10/15/2024 |
| Relief period end (5/1/2025) + 45 days | 6/15/2025 |
| Initial Payment during the Relief Period | |
| Qualifying Event date: | 10/1/2024 |
| COBRA Qualified Event Notice mailing date | 10/1/2024 |
| “Normal” time period for making initial payment | 45 days |
| Initial payment relief period + 45 days | 6/15/2025 |
| Required premiums with extended deadline | Oct 2024 through May 2025 |
| First premium with normal premium deadline | June 2025 |
| Ongoing Payment during the Relief Period | |
| Qualifying Event date | 8/1/2024 |
| COBRA Qualified Event Notice mailing date | 8/15/2024 |
| Participant elected | 9/1/2024 |
| Initial payment | 9/1/2024 |
| Next payment due date Relief Period + 30 days | 5/31/2025 |
| Required premiums with extended deadline | Oct 2024 through May 2025 Due 5/31/2025 |
| First premium with normal premium deadline | June 2025 |
Resources
Disaster Relief Notice 2024-01
Agencies Providing Notice: The public notice of relief was provided in Disaster Relief Notice 2024-01 and a related rule. These actions were taken jointly by the Employee Benefits Security Administration (EBSA), the Department of Labor (DOL), and the Department of Treasury and apply to certain ERISA employee benefit plans.