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.

Independence will honor employer requests to continue coverage for employees that are furloughed, temporarily laid off, or have experienced a reduction in hours that eliminates eligibility as a result of impacts of COVID-19. This exception applies to fully insured and self-funded business, and is contingent upon:

  • Full premium payments continue to be made by the group.
  • Self-funded groups must continue to remit invoiced amounts in full.
  • The group is responsible for collecting employee contributions, if applicable.
  • No reductions to employer contributions will be allowed.
  • Only actively at-work employees can be added to the plan as new enrollees. If an employee was in their probationary period at the time of the furlough or temporary layoff, they may be added to the benefit plan with appropriate documentation of their hire date.

HM Insurance Group (HMIG) will honor coverage in accordance with the above conditions. Self-funded employers who do NOT contract with HMIG for Stop Loss/Reinsurance, should contact their Stop Loss carrier or broker/consultant for information on how these benefits will be covered under their policy related to the specific Stop Loss contract terms and Plan documents.

Independence will honor employer requests to continue coverage for employees furloughed or temporarily laid off [or whose hours have been reduced] as a result of impacts of COVID-19, as long as premium payments continue to be made by the employer. Effective through September 30, 2020.

Groups may waive the waiting period for employees with a lapse in coverage due to a furlough or lay off if the waiver policy is applied consistently to all eligible employees.

Through September 30, 2020, if the loss of enrollment is a result of the COVID-19 crisis, rates and premiums will not change. Effective October 1, 2020, standard Underwriting Guidelines are applicable.

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.

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

At this time, we are asking that groups notify us only when employees need to be removed from the group plan. After October 1, 2020, Independence may perform audits to confirm enrolled employees are actively at work.

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.

COBRA eligibility is the responsibility of the group. Generally, loss of employment is considered a qualifying event. Furloughed and laid-off employees may also be eligible for individual ACA coverage.

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.

COVID-19 is having an unprecedented and significant impact on employers, employees, payors and providers with a broad range of potential outcomes. The extent to which claims costs will change is still unknown. Our focus has been on ensuring our members and their families have access to the care that they need and providers are able to treat our members without barriers. To ensure the health and wellness of our members, we have provided, for the noted pandemic time period:

  • no cost sharing for COVID-19 testing or in-network, inpatient acute treatment for COVID-19
  • prior authorization modifications to allow easier access to care
  • no cost sharing for telemedicine visits with network PCPs and MDLIVE
  • telemedicine access for specialists
  • premium access to a mindfulness app, offered at no cost for 60 days

With all the uncertainty, Independence is not in a position to change existing rates for insured groups during the course of their plan year. As a reminder, the Affordable Care Act provides guardrails in these types of situations. Should medical costs be significantly less than expected, premium rebates would be issued.

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.

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.

For large group, commissions are paid on a percent of premium basis. Since the premiums paid will be less, commissions will be reduced accordingly.

Customers that took advantage of the premium deferral program should continue to pay their deferred premium amounts. To remain current, these customers must pay at least one third of their deferred premium plus the amount due for their September premium. The September premium amount will include a one-time reduction based on the customer’s July 1, 2020 enrollment.

The premium credit is applicable for all customers that were enrolled with Independence as of July 1, 2020. In order to calculate and process the reduction on the September invoice, we had to base the enrollment on July membership. Any new customers that became effective in August would not receive a premium credit.

The premium credit applies to all large group (51+) fully insured groups regardless of the contract count.

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 30, 2020