Relief starts with a federal declaration and a published notice, not with a phone call.
Disaster relief for plans is tied to a declared disaster, the areas FEMA designates for individual assistance and a notice with an incident period and an end date. This page follows the chain and explains why to watch each notice.
Where This Page Fits.
General information, not legal advice. Each claim on this page is tied to the statute, rule or agency notice cited in the Laws And Sources section.
EBSA Disaster Relief For Group Health Plans
The overview: what disaster relief is, how a notice is built and what Michigan employers do before one is issued.
Health Plan Deadlines Extended In A Disaster
Which COBRA, special enrollment, claims, appeal and external review deadlines the joint notice can move, and what the ordinary clocks are.
Documenting And Restarting Deadlines After A Disaster
What to record, how to restart ordinary clocks and how contribution deposits fit.
From Declaration To Notice.
Relief begins with a federal declaration. ERISA section 518, 29 U.S.C. 1148, names three triggers: a Presidentially declared disaster, a terroristic or military action, or a public health emergency declared by the Secretary of Health and Human Services under 42 U.S.C. 247d. For disasters, the example notice we use tied coverage to major disasters declared under section 401 of the Stafford Act and to the areas FEMA identified for individual assistance.
EBSA then publishes a disaster relief notice, and for group health plans a joint notice goes out with Treasury and the IRS. The notice sets an incident period, which can start on a different date in each state or area, and an end date. Under Notice 2024-01 relief began on the first day of the incident period for the area and ended May 1, 2025, everywhere.
Why Each Notice Matters.
No two notices are the same. Each names its own disaster, places, dates and conditions, and the Department says it may issue additional relief as a situation develops. The first notice may not be the last word, and a plan that read it once and moved on can miss a later change.
The relief also comes through more than one channel. Group health deadlines sit in the joint notice, other Title I notices fall under section 518 relief in the EBSA notice, and filing dates for Form 5500 follow IRS releases. Employers who watch only one source miss the others.
Two Pages To Check.
The first is the EBSA disaster relief page on dol.gov, which lists the current notices. The second is the IRS page on tax relief in disaster situations. IRS announcements carry a code made of a state abbreviation, the year and a sequence number, and most state that various deadlines are postponed to a stated date. The IRS page points to a separate listing of the localities that qualify for each disaster.
When we last checked the EBSA page on October 27, 2026, it listed the Helene and Milton notice and Form 5500 filing extension information, and no Michigan declarations. That can change at any time, so look at the live page.
Common Misreadings.
Treating Notice 2024-01 as current. It applied to other states and expired May 1, 2025.
Waiting for a notice before preparing. The employers who restart cleanly are the ones who already knew their vendors, their contacts and their calendar.
Assuming one notice covers every deadline. Check the health plan notice, the Title I notice and the IRS release for the same event.
Related Rules And Tools.
A Compliance Calendar For Your Plan Year
A plan-year view of the dates that matter.
ERISA Compliance For Michigan Employers
The ERISA duties that apply to Michigan employers.
Michigan Employer COBRA Guide
Federal COBRA requirements from a Michigan employer’s view.
Employment Law For Michigan Employers
The wider map of employment law topics that touch benefits.
Laws And Sources
EBSA Disaster Relief Notice 2024-01: The worked example: Hurricanes Helene and Milton, the covered areas, incident periods, the May 1, 2025 end date and the conditions attached.
EBSA Disaster Relief Page: The Department of Labor list of current disaster relief notices. Check it for any Michigan declaration.
ERISA Section 518, 29 U.S.C. 1148: The statute that lets the Secretary of Labor disregard a period of up to one year for plans affected by a declared disaster.
Code Section 7508A, 26 U.S.C. 7508A: The Treasury authority to postpone tax-code deadlines, including plan deadlines, after a declared disaster.
IRS, Tax Relief In Disaster Situations: IRS disaster announcements, each with a state code, a locality list and postponed dates.
Quick Answers.
What triggers EBSA disaster relief for a health plan?
A federal declaration: a Presidentially declared disaster, a terroristic or military action, or a declared public health emergency under ERISA section 518. The example notice also tied relief to areas FEMA identified for individual assistance.
Is there a current disaster relief notice for Michigan employers?
We have not confirmed one. On October 27, 2026, the EBSA disaster relief page listed no Michigan declarations. Notice 2024-01 applied to other states and expired May 1, 2025.
Where do we find out about new disaster relief?
Check the EBSA disaster relief page on dol.gov and the IRS page on tax relief in disaster situations. Between them they cover the Department of Labor notices and the IRS postponements.
The Rest Of This Series.
ERISA Section 518 Relief For Plan Notices
How late notices and disclosures are excused when you act in good faith and deliver as soon as administratively practicable.
Electronic Delivery During A Disaster
When email, text messages and a website count as a good-faith way to reach participants, and how the safe harbor still works.
Form M-1 And Form 5500 Disaster Relief
How MEWA reports and annual returns follow IRS relief, and who counts as directly affected.
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