Question juridique clé
Whether the cantonal appeal against the insurer's objection decision was filed within the applicable deadline, including any Easter suspension period.
Solution extraite
The appeal was late because the applicable cantonal procedural law contained no positive rule suspending the 30-day deadline; Art. 41(3) VRPG was only declaratory and did not make the ATSG suspension rules directly applicable.
Motifs extraits
Under the transitional regime, pre-ATSG cantonal procedural rules remain applicable until adaptation, but only where they themselves provide for suspension or where federal law makes it applicable. The Bern provision merely incorporates the supremacy of federal law and has no independent content. The appeal was lodged one day after expiry of the 30-day period.