The COVID-19 crisis has been a roller coaster for employers as they’ve faced massive change at record speeds. During this time, health insurers have done their best to keep up and support not only employees and employers, but entire communities through their plans.
There have already been major coverage changes, including for the COVID-19 diagnosis process and treatment:
Coverage for diagnosis. For those facing illness due to the virus, coverage rules have been changing rapidly. Specifically, all private health plans, including both fully insured and self-funded employer groups, must:
- Cover COVID-19 diagnostic testing at no cost to the insured
- Cover the cost of any office, telehealth, urgent care or emergency room visit that triggers the need for testing at no cost to the insured; and
- Waive any prior authorization or medical management requirements associated with obtaining a COVID-19 diagnosis.
Coverage for treatment. The law currently requires treatment for COVID-19 to be covered at “no cost” to the insured. But most local health insurers, including CareFirst, Kaiser, and UnitedHealthcare, have indicated they will be waiving employee cost-sharing requirements related to COVID-19 treatments. This change won’t automatically apply to all health plans. This is because self-funded plan sponsors need to decide independently if they wish to amend cost sharing for COVID-19 treatments under their plans.
Many are choosing not to do so because it is unclear what the impact would be on plan costs. In other cases, employers are electing to waive certain coinsurance or copayment requirements— but only where funding allows, and when it is approved in advance by the employers’ stop-loss insurance carrier.
The past month has brought unprecedented numbers of layoffs and furloughs. This raises the question: what happens to those employees’ health insurance? The answer is that employers may have choices — and that is certainly welcome.
Generally, an employee who is no longer “actively at work” is not eligible to participate in an employer’s health plan under the terms of applicable documents, including insurance policies. This would mean that even if an employer intended to rehire an employee, it would have to terminate his or her benefits if they stopped working.
In light of this, employers facing layoffs or furloughs have several options:
- Maintain active coverage: Both fully insured carriers and stop-loss insurers have relaxed eligibility requirements to allow employees to maintain active employee coverage under their benefit plans even while they are not working. To take advantage of this option, which will likely help with employee retention issues in the long term, confirm that it’s available with your specific carrier and document the extension in writing.
- Continuation coverage. If plan eligibility rules aren’t changed,a furlough or layoff will typically trigger COBRA or Maryland Continuation Coverage (for employers with fewer than 20 employees). Employees are generally required to pay up to 102% of the cost coverage under these programs, but employers could elect to provide a subsidy to help offset these costs.
- Individual coverage option. A loss of coverage under an employer plan also triggers a right to enroll in individual coverage through the Maryland Health Benefit Exchange. In many cases, particularly for younger employees and/or instances when no employer subsidy is provided, this will be a better option than continuation coverage.
Employers may also wish to ask their brokers or insurance carriers about a few new programs allowing for a special period for previously unenrolled employees (and in some cases, uninsured dependents) to enroll in employer-sponsored group health plans and/or short-term deferrals on health insurance premiums.
Two months ago, I never would have believed these types of changes could happen this quickly — proof, perhaps, that necessity is the mother of invention.