Group Coverage Frequently Asked Questions About COVID-19

Below are frequently asked questions (FAQ) about how COVID-19 will affect employers with Independence Blue Cross group health insurance plans. Click on a topic below to view a list of related questions, then click on the question to view the answer.

As long as the group submits the premium in full, the employee and their dependents will be considered active. This includes COBRA enrollees.

If a group continues to pay the monthly invoice during the duration of the COVID-19 pandemic, Independence will assume the group intends to remain in business and will continue coverage. Upon any formal notice that the group has gone out of business, the plan will be terminated since it would no longer be a legally recognized group.

It is the group’s responsibility to collect employee premium contributions. Employers should continue to make full premium payments. Self-funded groups must continue to remit invoiced amounts in full.

Independence does not administer COBRA coverage. Groups should contact their COBRA administrator to determine eligibility under COBRA coverage.

For groups that have been forced to lay off employees, individual insurance may be a better option than COBRA to keep people insured. For more information on Independence options for individuals and families, please visit our COVID-19 resource page.

Benefit downgrades are permissible off anniversary for mid-market and large sized groups. For individual and small groups, the business-as-usual ACA requirements apply.

The changes to coverage as a result of COVID-19 do not limit or eliminate benefits or increase member cost-sharing. Therefore, carriers and self-funded groups are not required to issue revised SBCs. If carriers or self-funded groups were to maintain the revised-for-COVID-19 coverage after the public health emergency, SBCs would need to be reissued.

Yes, uninsured Americans can receive testing and treatment for COVID-19 as mandated by Federal legislation during the emergency period.

Yes. We are waiving cost-sharing for Urgent Care visits, if the visit is to test for COVID-19.

Independence will cover the cost of health care providers administering the COVID‑19 vaccine with no cost‑sharing to our members, in accordance with federal and state laws and regulations. As vaccines are approved by the Food and Drug Administration (FDA) for Emergency Use Authorization (EUA), the federal government will supply the vaccine to health care providers at no cost. For more information on the COVID-19 vaccine, see the below resources:


Since the coverage changes related to COVID-19 are the result of federal guidance (IRS guidance concerning HDHPs) or federal law (Families First), Independence is not required to amend the Administrative Services Agreement (ASA). The ASA has several compliance with law provisions that require that both Independence and the self-funded group comply with applicable law.

Most employers manage the plan document that is submitted to Stop Loss carriers, so there are no plans for Independence to create amendments.

The cost will vary by group. Independence is working on reports to help groups better understand financial impacts.

Independence will provide de-identified aggregate reporting on COVID-19 related costs.

Under ERISA, if an employer is materially reducing an employee’s benefits, a group must notify the member within 60 days of the material reduction. However, the changes in coverage related to COVID-19 are a benefit enhancement for the group’s employees, not a reduction. Generally, groups have 210 days after the end of the plan year to notify members of material changes to the plan. For groups with a January 1 plan year, the notice of material change must be sent by August 1, 2021. While we cannot provide legal advice to groups about ERISA, we do not believe the coverage changes related to COVID-19 will create any ERISA compliance issues for groups.

Independence is only waiving cost-sharing on primary care telemedicine visits. Telemedicine visits with specialists and behavioral health providers are subject to the cost-sharing under the member's benefit plan.

It is advised that groups share information about a positive diagnosis to those who may have come into contact with an employee who tests positive, using discretion so as not to disclose the employee’s identity.


Telemedicine visits with non-participating providers are covered for members with out-of-network coverage. Visits are subject to the out-of-network cost-sharing under the member’s benefit plan. This applies to specialists as well as behavioral health providers.

Testing is offered at a number of locations. Independence will provide this testing at no cost to the member.

MDLIVE offers members the experience of completing a brief questionnaire about their symptoms, and then requesting time with a doctor for the next available time slot. In most cases, these are within four hours, and this allows the member to rest or relax comfortably at home for the doctor’s evaluation, vs in a waiting room.

MDLIVE does not offer disability paperwork or provide doctor’s notes for work absences.

Yes, HIPAA requirements still apply, however we have received guidance from the Health and Human Services Office for Civil Rights (OCR) that they will exercise enforcement discretion and waive penalties for HIPAA violations against health care providers that serve patients in good faith through everyday communications technologies, such as FaceTime or Skype, during the COVID-19 pandemic.

Yes. In an abundance of caution, Independence has put quantity level limits on certain medications to help prevent shortages. To date, we placed quantity limits on albuterol inhalers, azithromycin, hydroxychloroquine, and chloroquine for Commercial business. We will continue to monitor potential specific drug shortages and/or inappropriate utilization.

COVID-19 coverage is in accordance with the public health emergency (PHE), which is currently scheduled through October 31, 2021:

Member cost-sharing is waived for telemedicine visits with plan members’ existing PCPs and specialists for a COVID-19 diagnosis only.

Member cost-sharing is waived for telemedicine visits with plan members’ Behavioral Health specialists for COVID-19 behavioral health related services.

For fully insured accounts and members, member cost-sharing is waived for all MDLIVE telemedicine visits until the customer’s 2021 renewal. Consumer, small group, and large group standard plan designs will have $0 cost-sharing for MDLIVE visits at renewal for all diagnosis. 51+ groups with custom benefits that had MDLIVE coverage prior to COVID-19 will revert to their plan’s cost-share upon renewal for a non-COVID-19 diagnosis. Member cost-share will continue to be waived for a COVID-19 diagnosis.

For self-funded accounts and members, member cost-sharing is waived for all MDLIVE telemedicine visits until the customer’s 2021 renewal. Once the customer group renews, the plan’s member cost-share will apply for a non-COVID-19 diagnosis. Member cost-share will continue to be waived for a COVID-19 diagnosis.


Please note: Employers are advised to consult with their legal counsel and/or tax advisor to determine if their benefit offerings meet applicable state and federal requirements.

Last updated: July 1, 2021