Agent COVID-19 Q&A 

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On May 4, 2020, the Department of the Treasury and the Department of Labor (the departments) published a final rule that temporarily extends timeframes normally applicable to group health plans under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). If you would like to review the final rule, it is publicly available in the Federal Register. 

On June 10, 2020, the Wisconsin Office of the Commissioner (OCI) issued a Notice to Issuers (notice) requesting that Wisconsin issuers extend the same flexibility granted by the federal government to members of group health plans subject to COBRA to non-ERISA group health plans and grandfathered plans, which are exempt from COBRA but subject to State continuation laws. 

Dean Health Plan does not administer COBRA or State continuation on behalf of its group health plan clients. The plan sponsor (employer) may administer its own continuation benefits or contract with a COBRA Administrator to do so on its behalf. Dean Health Plan administers continuation coverage as directed by the plan sponsor or the group’s COBRA Administrator, while adhering to all applicable laws and regulations. Dean Health Plan's existing process for administration of COBRA and State continuation coverage will remain unchanged as it is not impacted by the change in timeframe extensions set forth in the departments’ final rule or OCI’s Notice. 

Please note, the final rule and Notice will not impact our application of the Group Master Policy, including application of retroactive premium adjustments. We will refund or adjust premium retroactively for up to a three-month period in which the employer or member provides notice of change to, or termination of, coverage for a member or employer as outlined in the Group Master Policy. If you have additional questions regarding the Group Master Policy, please contact the group’s Client Service Representative. 

On May 4, 2020, the Department of the Treasury and the Department of Labor (the Departments) published a final rule that temporarily extends special enrollment period (SEP) timeframes. 

For plans subject to Health Insurance Portability and Accountability Act (HIPAA) SEP rules, when calculating the appropriate SEP time period Dean Health Plan will disregard the period from March 1, 2020 through up to 60 days after the announced end of the National Emergency declaration, or through an alternative date subsequently announced by the Departments. 

For example, if an employee eligible for employer-sponsored group health insurance declined coverage when last eligible to enroll then gave birth to a child on March 31, 2020, the employee is eligible for a special enrollment for up to 30 days after the National Emergency ends, assuming premiums are paid for any period of coverage.

On May 4, 2020, the Department of the Treasury and the Department of Labor (the Departments) published a final rule that temporarily extends appeal submission and completion timeframes.

For plans subject to federal appeals procedures (as described in the final rule), when calculating the appropriate appeals submission or completion time period Dean Health Plan will disregard the period from March 1, 2020 through up to 60 days after the announced end of the National Emergency declaration, or through an alternative date subsequently announced by the Departments.

On June 10, 2020, the Wisconsin Office of the Commissioner (OCI) issued a Notice to Issuers (Notice) requesting that Wisconsin issuers extend the same flexibility related to extended appeal submission and completion timelines available to ERISA group plans to non-ERISA group plans and grandfathered plans. Wisconsin State law does not provide for timeframe restrictions on filing of grievances and appeals. However, State law does provide that a request for independent review must occur within four months after the member receives notice of disposition of their grievance. The Notice requests that the independent review timeframe be extended consistent with the Departments’ final rule.

Due to the COVID-19 pandemic, since March 17, 2020 Dean Health Plan has been extending PA timeframes to allow additional time to have services completed. We have notified in-network providers of our PA timeframe extensions. If you have additional questions regarding PA timeframe extensions, contact to your Client Service Representative. 

On May 4, 2020, the Department of the Treasury and the Department of Labor (the departments) published a final rule temporarily extending claims submission timeframes.

For plans subject to ERISA claims procedure (as described in the final rule), when calculating the 365-day claims submission time period Dean Health Plan will disregard the period from March 1, 2020 through up to 60 days after the announced end of the National Emergency declaration, or through an alternative date subsequently announced by the departments. 
 

Large group premium payments are subject to our current non-payment policy. Contact your Client Service Representative to discuss your large group client’s specific needs.

Small group employers that are not currently in a grace period and are experiencing financial hardship due to the COVID-19 pandemic are eligible for a 30-day premium due date deferral. After the 30-day deferral period, if premium is not paid in full the small employer will enter a 30-day grace period and all standard non-payment policies will apply. Contact your Client Service Representative to discuss your small group client’s specific needs.

Individuals who are not currently in a grace period and are experiencing financial hardship due to the COVID-19 pandemic are eligible for a 30-day premium due date deferral. After the 30-day deferral period, if premium is not paid in full the individual will enter their contractual grace period and all standard non-payment policies will apply. Premium payment deferrals are not available to Medicare Gold, Medicare Select, or Medicare Advantage members. Contact your Client Service Representative to discuss your individual client’s specific needs.

Currently, we will cover in-network screening and testing with no member cost share.

Currently, we will cover in-network hospitalizations for COVID-19 with no member cost share.

Individuals and small groups that are in a grace period are not eligible to defer premium payments. If the individual or small group pays all past due premiums, they will be removed from grace period status.

For individuals, our standard special enrollment policies remain in place. The Trump Administration recently indicated they will not authorize CMS to create a special enrollment period to allow uninsured Americans who do not qualify for standard special enrollment to enroll through healthcare.gov during the COVID-19 pandemic.

For groups, we do not intend to open a universal COVID-19 special enrollment period for employees who previously waived coverage and have not experienced a qualifying event, contact your Client Service Representative for more information.

For the duration of the public health emergency, an employee’s coverage will continue regardless of how many hours the employee works if the employer continues to classify them as an active employee and pay the premium.

Individuals may have several coverage options available to them, such as,

For individuals, premium payments can be made online through the Dean Health Plan or Prevea360 Health Plan member portal, by mail, or through automatic withdrawals from a checking or savings account. During normal circumstances we also allow in person premium payments; however, during the public health emergency this option is unavailable.

For employers, premium payments can be made by mail or through an automatic electronic payment (ACH). If your client has not already set up ACH and would like to do so contact your Client Service Representative.

We do not expect timing for 2020 renewals to change.

At the employer’s request, we will waive waiting periods for employees who are laid off temporarily as a result of the COVID-19 public health emergency. If your client would like to waive waiting periods, reach out to your Client Service Representative.

As long as the employer group still has an active plan with us, COBRA/Continuation will be available to any furloughed employees.

If an employee is furloughed during the public health emergency and later returns as an eligible employee, their accumulators will continue consistent with standard renewal cycles.

During the public health emergency groups will not be termed for failure to meet participation requirements. Impacted groups will be considered on a case by case basis at the time of renewal.

As you know, during the COVID-19 public health emergency, medically necessary services that can be safely delayed are in many cases being postponed to ensure essential health care services are available to patients in need. These postponements also help support social distancing and slow the spread of COVID-19. We understand that this means certain services may be temporarily unavailable.

This delay may result in a temporary reduction in claims costs related to these services. When providers return to normal operations, we expect there will be an increased demand for routine and specialty medical services. Because these services will be available when the public health emergency is lifted and we expect our members to ultimately access all medically necessary services, we believe premiums to be appropriate and do not at this time intend to make temporary adjustments.

During this time, we encourage members to contact in-network medical care providers to determine whether services can be provided remotely through video and/or audio technologies. Your employees can also use e-visit, available through deancare.com. e-visit offers care for common conditions such as urinary tract infection, pink eye and acid reflux.

If e-visit or telehealth options are not a possibility, services may need to be delayed until after the public health emergency is lifted.

If a Marketplace member experiences a change in income, they may access Healthcare.gov to update their income and determine if they qualify for additional subsidies.

To limit potential COVID-19 risk, we have expanded our coverage of telehealth services during the public health emergency. This will allow additional methods of health care access for members such as Skype, FaceTime, or Zoom. This policy applies to our commercial fully-insured members, Marketplace members, Medicare, and BadgerCare Plus (Medicaid) members.

In alignment with CMS, we are offering several services members normally receive at our care delivery sites through telehealth. This includes primary care visits, behavioral health sessions, physical therapy, occupational therapy, speech therapy, and many more. Members should outreach to their provider to determine if the services they need may be provided through a telehealth option. Standard member cost sharing applies for telehealth visits not related to COVID-19 screening or testing.

We can provide this information. Contact your Client Services Representative to make a request.

We can offer flexibility on enrollment for new hires. Contact your Client Service Representative to discuss your group client’s specific circumstances.

During the public health emergency, we will cover COVID-19 antibody testing and related services with no member cost share.