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Medical Carrier Premium Delay and Assistance

Aetna (March 27th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

Cigna (March 27th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

EMI (March 27th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

MotivHealth (March 27th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

Regence (March 25th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

SelectHealth (March 25th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

UHC (March 27th)

Exception requests on premium payments will be reviewed on a case-by-case basis, based on the employer’s specific circumstances.

Medical Carrier Furlough and Rehire Policies

Aetna response (March 19th)

As of now we are reviewing this by a case by case basis, so it will depend on the group (size, funding arrangement, whether or not employer intends on paying full premium etc.). I’ll let you know as soon as we have a company-wide protocol, but it will most likely remain a case by case basis.

> Aetna Policy

Cigna response (March 19th)

Temporary Layoff or Leave of Absence – If your Active Service ends due to temporary layoff or leave of absence, your insurance will be continued until the date your Employer stops paying premium for you; or otherwise cancels your insurance. However, your insurance will not be continued for more than 60 days past the date your Active Service ends.

EMI response (March 18th)

To comply with ACA, we should stay within the window of 13 weeks. So, if an employee is re-hired within 13 weeks of their original termination date, they would not need to re-satisfy their eligibility new hire waiting period. Anyone hired after 13 weeks, will be treated as a new hire and need to re-satisfy their new hire waiting eligibility period.

MotivHealth response (March 19th)

That will vary based on the employer policy in place. It’s at the employer’s discretion. With that said, MotivHealth reserves the right to approve any changes, outside of the established policy, to ensure ACA compliance and to evaluate risk should changes be introduced outside of open enrollment.

Regence response (March 19th)

The re-hire policy for small group is if they are hired back within 3 months, they can re-fill out an application showing their re-hire date, then they will be effective first of the month following re-hire date.

If the employer can afford to keep paying the employee premiums, they can keep the employee covered for up to 12 weeks.

SelectHealth response (March 19)

There are three things that the groups can do.

  • They have a 60 day leave of absence available in the small group contract this option requires premium to paid while the employee is on leave.
  • If an employee is terminated and rehired within 30 days their coverage can be reinstated.
  • If an employee is terminated and rehired after 30 days but within 13 weeks the employees new hire waiting period can be waived.

Carrier Resource Centers

Aetna

> CVS Health Response to the COVID-19 Outbreak

Cigna

> Coronavirus Resource Center

EMI Health

> Coronavirus updates and resources

> Special COVID-19 Coverage Testing and Treatment

MotivHealth

> Coronavirus: Information & Preparedness

Regence BlueCross BlueShield

> Options and Information for Employers

> Coronavirus: How We’re Responding to COVID-19

SelectHealth

> SelectHealth Update: COVID-19 (novel coronavirus)

United Healthcare

> Important Information for Members from UnitedHealthcare on COVID-19

U of U Health Plans

> U of U Health Plans Coverage & Care Updates Re: COVID-19

Utah Insurance Department Carrier Survey about COVID-19 Coverage

Aetna

> UID survey responses

Cigna

> UID survey responses

EMI Health

> UID survey responses

MotivHealth

> UID survey responses

Regence BlueCross BlueShield

> UID survey responses

SelectHealth

> UID survey responses

> UID survey responses (short-term limited duration plans)

United Healthcare

> UID survey responses

University of Utah Health Plans

> UID survey responses

Medical Plan Coronavirus Questions

How is Coronavirus covered on my fully insured medical plan?

For most medical carriers the COVID-19 diagnostic test, the office visit, and telehealth services are now available at no cost to members.  We recommend visiting your carriers dedicated COVID 19 resource page to see how your carrier is specifically handling this unprecedented event.

Regence Coronavirus Resource Center

Aetna Coronavirus Resource Center

Cigna Coronavirus Resource Center

SelectHealth Coronavirus Resource Center

Motiv Coronavirus Resource Center

United Healthcare Coronavirus Resource Center

How will my CDHP/HSA plan handle the cost of testing and treatment for COVID-19? Will I be required to meet my full deductible?

The IRS released Notice 2020-15 to facilitate proactive COVID-19 testing for those individuals participating in a CDHP Health Savings Account plan.  This is important to note so that individuals enrolled in such plans DO NOT have to meet their annual deductible for the plan to cover such expenses as testing and vaccinations (assuming one is created for the virus) related to the virus.  This will hopefully encourage individuals who feel they may have symptoms of the virus to be treated early without the fear of incurring additional out-of-pocket costs.

If our employees are no longer actively working, are they still entitled to group health plan coverage?

Not necessarily. You need to check your group health plan document (or certificate of coverage if your plan is fully insured) to determine how long employees who are not actively working may remain covered by your group health plan. Once this period expires, active employee coverage must be terminated (unless the insurance carrier or self-funded plan sponsor otherwise agrees to temporarily waive applicable eligibility provisions), and a COBRA notice must be sent. If your plan is self-funded and you would like to waive applicable plan eligibility provisions, you should first make sure that any stop-loss coverage insurance carriers agree to cover claims relating to participants who would otherwise be ineligible for coverage.

Please contact your FBA account team for confirmation as to how your self-insured plan will handle such claims.

What happens to group health plan coverage if employees are not working and unable to pay their share of premiums?

In the normal course of events, group health plan coverage will cease when an employee’s share of premiums is not timely paid. However, several actions might be taken that could allow coverage to continue.

First, the insurance carrier providing the health coverage may voluntarily continue the coverage while the disaster is sorted out and until an employer reopens its doors. More likely, the employer may make an arrangement with the insurance carrier providing health coverage to pay the employees’ share of premiums to keep coverage in place (at least temporarily) and possibly until the employer can reopen its doors. Each situation will be different, depending upon the insurance carrier and the relationship between the employer and the insurance carrier. Therefore, each factual situation will need to be individually assessed.

Health Savings Accounts

HealthEquity CARES Act

> HealthEquity CARES Act Updates on Health Savings Account Changes

Self-Insured Medical Plan Coronavirus Questions

How is Coronavirus covered on my self insured medical plan?

Coronavirus will currently be covered like any other illness and follow your plan document for office visits and hospitalizations.  This is subject to change especially with government intervention as a possibility.

How will my self-insured plan handle the cost of testing and treatment for COVID-19?

Employers under a self-insured health plan should check with their providers to determine how they are addressing cost-sharing related to COVID-19 screening. These employers should also determine what actions must be taken to elect in or out of the 2019 Novel Coronavirus testing cost-sharing programs.  Under a self-insured platform there is more flexibility with how such expenses will be handled.

Please contact your FBA account team for confirmation as to how your self-insured plan will handle such claims.

How will my CDHP/HSA plan handle the cost of testing and treatment for COVID-19? Will I be required to meet my full deductible?

The IRS released Notice 2020-15 to facilitate proactive COVID-19 testing for those individuals participating in a CDHP Health Savings Account plan.  This is important to note so that individuals enrolled in such plans DO NOT have to meet their annual deductible for the plan to cover such expenses as testing and vaccinations (assuming one is created for the virus) related to the virus.  This will hopefully encourage individuals who feel they may have symptoms of the virus to be treated early without the fear of incurring additional out-of-pocket costs.

If our employees are no longer actively working, are they still entitled to group health plan coverage?

Not necessarily. You need to check your group health plan document (or certificate of coverage if your plan is fully insured) to determine how long employees who are not actively working may remain covered by your group health plan. Once this period expires, active employee coverage must be terminated (unless the insurance carrier or self-funded plan sponsor otherwise agrees to temporarily waive applicable eligibility provisions), and a COBRA notice must be sent. If your plan is self-funded and you would like to waive applicable plan eligibility provisions, you should first make sure that any stop-loss coverage insurance carriers agree to cover claims relating to participants who would otherwise be ineligible for coverage. Please contact your Account Executive for help working through these specific issues.

What happens to group health plan coverage if employees are not working and unable to pay their share of premiums?

In the normal course of events, group health plan coverage will cease when an employee’s share of premiums is not timely paid. However, several actions might be taken that could allow coverage to continue.

First, the insurance carrier providing the health coverage may voluntarily continue the coverage while the disaster is sorted out and until an employer reopens its doors. More likely, the employer may make an arrangement with the insurance carrier providing health coverage to pay the employees’ share of premiums to keep coverage in place (at least temporarily) and possibly until the employer can reopen its doors. Each situation will be different, depending upon the insurance carrier and the relationship between the employer and the insurance carrier. Therefore, each factual situation will need to be individually assessed.

What is the estimated HealthPlan cost of the Coronavirus?
The Society of Actuaries created the attached brief outlining the impact of COVID-19.

Disability

Is an employee who is quarantined but not sick or diagnosed with the coronavirus considered “disabled”?

Generally, carriers do not consider quarantined workers to be disabled unless they have a medical condition that results in restrictions and limitations that satisfy a policy’s definition of disability.

Is the coronavirus infection covered under Short-term Disability or Long-term Disability policies?

Coronavirus would be treated no differently than any other covered illness under most STD and LTD plans.   If a person is diagnosed with coronavirus, a claim for STD or LTD benefits could be payable after the elimination period if the definition of disability has been met, i.e. if they are unable to work because of the coronavirus infection.  If, after diagnosis, they remain able to perform work duties (even if quarantined and working from home) the employee would generally not be considered Partially or Totally Disabled.  Additionally, individuals who are self-quarantined without a diagnosis and not sick would not have a payable claim situation.

Prior to any new legislation adopted to address the Coronavirus issue, would an employee be considered eligible for a leave (paid or unpaid) under a federal or state leave program if local health departments or law enforcement agencies required an exposed person to stay home under quarantine during a prescribed incubation period?

Under federal and state statutory leave laws, an FML administrator can generally approve a claim when a claimant meets the definition of Serious Health Condition under the applicable federal/state statute. Under these statutory programs, there is an expectation that benefits will be administered on a consistent basis no matter the underlying illness. As with disability claims, each leave is decided on its own specific facts. In general, however, employees are not entitled to federal or state leave to stay home during a quarantine period if they are not ill. It is important to monitor legislation adopted after February 2020 for up to date information.

Do long-term care insurance policies cover Coronavirus?

A Long-Term Care claim filed by individual diagnosed with coronavirus would likely be payable if they meet the policy definition and they are receiving covered services.  If a claimant is quarantined and not receiving covered services, no benefits would likely be payable. 

How do employers manage disability and the ADA if employees have personal travel / pto time outside of the state or into affected areas?

At FBA, we know there are several questions that come up regarding disability and the Department of Labor Americans with Disabilities Act (ADA).  We have seen questions come up regarding personal travel (Spring Break) and how it may or may not impact disability related issues specific to the virus.  For legal guidance, we recommend that you reach out to your counsel to appropriately establish guidelines and communication.  To aid in those conversations with your legal team, you may find the following comments from the Law and Workplace attorneys at Proskauer Law firm a helpful tool.

According to Proskauer law firm, “while employers may implement restrictions on work-related travel to affected areas, employers should tread more carefully when attempting to police personal, non-work-related travel. “

“… it is worth noting that the EEOC has argued on at least one occasion that an employer acting on a potential future health condition may be viewed as “regarding” an employee as disabled as long as the condition otherwise qualifies as a disability under the law.  For this reason, employers should consider the risks (as well as the practicalities) relating to imposing a ban on personal, non-work-related travel to affected areas.  However, as discussed further below, employers may require employees engaging in travel to these areas to remain out of the workplace for at least 14 days upon their return.”

“the ADA prohibits employers from making disability-related inquiries and requiring medical examinations, unless (1) the employer can show that the inquiry or exam is job-related and consistent with business necessity, or (2) where the employer has a reasonable belief that the employee poses a direct threat to the health or safety of the individual or others that cannot otherwise be eliminated or reduced by reasonable accommodation.”

https://www.lawandtheworkplace.com/2020/01/coronavirus-and-the-workplace-what-employers-need-to-know/

Pharmacy, Prescriptions and Refills

Is there a potential shortage in the drug supply chain?

As of February 27th, only one drug shortage due to COVID-19 has been reported by the FDA. The agency did not identify the particular drug but stated that alternatives were available. The FDA has asked over 180 drug manufacturers to evaluate their entire supply chain. With increased attention to the potential for shortages, employers should be aware of the risk and consider strategies to ensure their members’ well-being. Members are also encouraged to discuss therapeutic alternatives with their physician should disruption to the supply chain occur.

What should my client consider to prevent member access issues to their medications?

Employers should evaluate the all the potential barriers in place that may restrict pharmacists and patients from filling prescriptions. Depending on the capability of their PBM, employers can implement these strategies: make edits to their plan’s “refill too soon” utilization percentage, permit emergency refills, allow maximum extended day supply at the time of the refill, and/or waive processing restrictions for out-of-network pharmacies.

COVID-19/Coronavirus Testing

How much does a test kit cost?

For those with insurance, the cost is covered 100% by your medical insurance plan. For those without medical coverage and you are exhibiting one or more symptoms, testing will most likely be covered by your local health department at no cost.  In Utah, it is recommended you take the confidential self-test prior to seeking medical care so that you can be directed to the appropriate level of care.  In other states, visit your respective state Coronavirus resource page for testing instructions.  If you are experiencing a medical emergency, call 9-1-1 immediately.  At this time, it is not recommended that you order and pay for a self-test kit as tracking and containing the spread of this disease is a critical function of each state government’s Department of Health.

> Department of Labor (DOL) FDA Approves 45 minute and 15 minute Coronavirus test

Where and How Do I Get Tested?
  • Check to see if your symptoms require testing by visiting the CDC website or downloading the Apple App approved by the CDC:> Internet – CDC website> Apple iOS App
  • HOW – If you are symptomatic, call your doctor or your local health department if you are symptomatic to discuss whether you should be evaluated in person and considered for testing.
  • WHAT IF? – Patients who don’t meet priority requirements or do not have insurance can consider testing at commercial labs at their own cost.
  • For more information, visit coronavirus.utah.gov or the CDC at https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/index.html
How does it typically take to receive the test results back?

Originally, the test was taking 3 to 4 days to get returned, but that was due to low lab capacity. Most recently, it is common to get the test results back in 24 to 48 hours. Two new tests that have been approved by the FDA are beginning to be distributed to testing centers that can have results back in 15 to 45 minutes respectively.

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