AGA Health Insurance Update for COVID-19

On March 18, 2020, President Trump signed H.R. 6201, cited as the Families First Coronavirus Response Act, to be effective no later than April 2, 2020. This act outlines a number of items relating to employee benefits, including provisions on health plan coverage for COVID-19 testing.  There are three main items to be aware of and consider in this environment.

  1. Health plans must cover 100% of COVID-19 testing cost

All health plans, including self-funded plans (Grandfathered and Non-Grandfathered), must cover testing for COVID-19 with no cost sharing to the health plan member.

The act prohibits health plans from imposing any cost sharing (deductible, copays or coinsurance) for any testing and or visit resulting from a COVID-19 test. The health plan will cover 100% of the cost of the visit and the test, no matter what setting the COVID-19 testing takes place. Visits can be completed in person, at an urgent care, an emergency room, or through telemedicine.

The act also prohibits any health plan from having prior authorization or other medical management requirements for the testing of COVID-19.

No amendment will need to be added to your self-funded health plan to stay in compliance with the above provisions. Automated Group Administration, Inc. will process any testing related claims with codes for COVID-19 at a 100% benefit level for the health-plan member.

  1. Review health plan active at work provision relating to layoff, reduction of hours, or extended sick time

Another timely item affecting the health plan is the definition of active at work. Your health plan document has provisions for an employee, who is not actively at work or has had a reduction in hours to remain eligible for the health plan.  Most plans have a 1-month period before the employee would have to terminate from the plan and go through the COBRA procedures. Most plans further allow someone who is not actively at work, but is still receiving wage or salary, to stay on the plan for 3 months (or an extended longer period for some plans) before having to terminate and elect COBRA. We have worked diligently with our re-insurance carriers, and they have agreed to allow unemployment benefits to be considered wage or salary during this trying time. If a health plan chooses to allow this, members can stay on the plan for up to 3 months, for most plans, without having to go through the COBRA process.

Obviously, the employer can continue the current practice of terminating and offering COBRA to a member that is not actively at work.  In addition, any employee that is terminating employment will go through the normal termination plan provisions and be offered COBRA, if appropriate.

  1. Review Telemedicine Coverage

It is required that telemedicine for COVID-19 testing be included by your plan at no cost to the member.   Many plans also have implemented our HealthiestYou product that expands telemedicine services to all appropriate conditions. This service can be accessed 24/7 at no cost to the members.  This has been very popular over the last several years, and we have had very positive feedback during the recent increase of respiratory visits.

We have had many members and providers inquiring about benefits for physician office visits when the physician is not physically present.  The majority of health plans nationwide do NOT provide this service within the plan.  With the increase in the number of physician offices and practices being temporarily closed to physical visits, several providers have decided to provide direct tele-visits for their current patient base.  While not every service or specialty may be reasonable to complete by telemedicine, there are a number of services, covered by a health plan, that may be appropriate.  Those services may include follow up office visits or mental health visits for continuation of treatment plans. For some of these situations, continuity of care is a crucial aspect of a member’s care plan.

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