COVID-19 and Employee Health Benefits: Health Insurance Plan Enrollment and Continuation Deadlines Extended
Arizona group health plan administrators have a lot on their plates these days relating to COVID-19 and employee health benefits. This includes answering questions from participants concerned about losing coverage due to furloughs, layoffs, or other disruptions to their employment situation.
Because of the COVID-19 pandemic and the ensuing challenges faced by millions of workers, many of the rules, deadlines, and legal requirements that govern health insurance plans and employee rights may now create undue burdens for administrators and covered employees.
To avoid such hardships, the federal agencies responsible for regulating group health plans recently extended several deadlines to provide more flexibility relating to special enrollment periods, COBRA continuation benefits, and claims.
New COVID-19 and Employee Health Benefits Rules
On May 4th, 2020, the Internal Revenue Service (IRS) and the Employee Benefits Security Administration (EBSA) announced the extension of certain timeframes and deadlines for group health plans under the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code.
In their joint announcement, the agencies expressed concern that because of the economic upheaval caused by COVID-19, “participants and beneficiaries covered by group health plans…may encounter problems in exercising their health coverage portability and continuation coverage rights, or in filing or perfecting their benefit claims.” They also noted that “affected group health plans may have difficulty in complying with certain notice obligations” because of the Coronavirus pandemic.
Accordingly, the IRS and EBSA decided to “take steps to minimize the possibility of individuals losing benefits because of a failure to comply with certain pre-established timeframes.”
Modifications to HIPAA Special Enrollment Periods
To protect the portability of employer-provided health coverage, the Health Insurance Portability and Accountability Act of 1996 (HIPAA) requires plans to open special enrollment periods for employees under certain designated circumstances or if they experience certain life events.
An employee’s or dependent’s loss of eligibility for a group health plan or other health insurance coverage in which they were previously enrolled in one such situation. Employers are also required to provide a special enrollment period when an eligible employee wants to add a dependent to their coverage because of the birth of a child, marriage, adoption, or placement for adoption.
Generally, Arizona group health plans must allow such employees to enroll in the group health insurance plan if they are otherwise eligible and if they request enrollment within 30 days of the qualifying event.
Now, when calculating that 30-day enrollment window, plan administrators must disregard the period from March 1st, 2020 until 60 days after the announced end of the National Emergency, declared on March 13th, 2020, or any other date designated by the agencies (the “Outbreak Period”).
COBRA Continuation Coverage: Disregard Outbreak Period
Qualified Arizona medical insurance plan beneficiaries generally have at least 60 days to elect COBRA continuation coverage under a group healthcare plan. Health insurance plans also cannot mandate that employees pay premiums for COBRA coverage earlier than 45 days after the employee makes their initial election. The law also requires plans to notify qualified beneficiaries of their right to elect COBRA continuation coverage within specific time periods.
As with special enrollment periods, administrators should disregard the time between March 1st and the declared end of the Outbreak Period when calculating the 60-day election period for COBRA continuation coverage or the date for making COBRA premium payments.
Health Benefits Claim Times Modified
Plans for Arizona employee health insurance will also exclude the Outbreak Period when calculating the date within which employees can file benefits claims under the plan’s claims procedure, as well as the time within which claimants may appeal an adverse benefit determination.
Arizona Plan Administrators Can Turn to Us With Questions About COVID-19 and Employee Health Benefits
All of us are living through unprecedented and scary times. At Anderson Insurance Services, an experienced Arizona small business and individual health insurance broker, we remain committed to providing our clients with answers to all of their COVID-19 questions. Operating seamlessly and remotely, we can help you develop and implement health insurance solutions that will keep you and your Arizona workforce safe and healthy.
Contact Anderson Insurance Services today to schedule a free consultation about your small business or individual health insurance needs.