COVID-19 Employer Questions
We recognize the unprecedented circumstances employers are facing with the COVID-19 pandemic, and we want to work with our employer groups to provide as much flexibility as possible to maximize coverage for your employees in the current environment.
We are taking the steps we believe are permissible at this time, and we will monitor regulatory guidance to understand the extent to which we can continue providing this interim flexibility. Any temporary policy changes we make are conditioned on regulatory acceptance and are subject to change if we are so directed by state or federal regulators.
We will continue to provide updates here; we encourage you to check regularly. As always, thank you for placing your trust in HealthPartners.
For information on prevention, symptoms and what to do if you’re feeling sick, visit our COVID-19 information page.
Frequently Asked Questions
Below are answers to some of the most common questions we’ve received.
Changes in Employee Status
Q: What is the difference between a furlough, a temporary layoff and a permanent layoff?
A: Furlough is a mandatory leave of absence imposed by the employer, typically for business or economic reasons, where employment has not been terminated.
Temporary layoff is a termination of employment with the hope that the employee will be rehired or recalled at some point in the near future (e.g., within 6 months).
Permanent layoff is a termination of employment with no specific intent to rehire or recall the employee to work.
Q: If employees are still employed but not working the same hours or not actively working at this time, are they eligible to stay on the plan?
A: We’re allowing flexibility in the plan eligibility definition as long as premium payments continue on the same basis as they currently do. That includes the contribution amounts from the employer and employee remaining the same. See question on premium amounts below.
Q: If employees are on furlough, would they be eligible to stay on the plan?
A: If your group is furloughing employees, we’re allowing flexibility in the plan eligibility definition as long as premium payments continue on the same basis as they currently do.
Q: If employees are not meeting the hourly requirement for eligibility, can they stay on the plan?
A: If your group is temporarily reducing hours for employees, we’re allowing flexibility in eligibility definition as long as premium payments continue on the same basis as they currently do.
Q: Can groups change the amount of premium paid by employer versus employee during this time?
A: Not without an underwriting review. The percentages of premium paid by each should remain what they are today. For example, if the employer contributes 75 percent and the employee contributes 25 percent, those should remain the same. If a group wants to continue coverage but change the contribution percentages, it needs an underwriting review.
Q: If employees are on laid off, would they be eligible to stay on the plan or should they be changed to COBRA status?
A: If your group is terminating/laying off employees, COBRA applies. Individuals may obtain coverage on the Individual market, which may be subsidy-eligible based on income. At least one employee must remain on the group plan to maintain the policy.
Q: Can employers keep their policies active if there are no employees employed?
A: If there are no active employees, the group would need to terminate coverage. If your group is terminating coverage, standard contract termination provisions apply. In this case, COBRA does not apply. Individuals may obtain coverage on the Individual market, which may be subsidy-eligible based on income.
Q: If employees are currently not working due to FMLA, disability or other unique circumstances, are they eligible to stay on the plan?
A: These situations would be unique to each employer. We cannot provide advice on FMLA or disability matters. Employers should speak to their own legal counsel, trade groups or consult regulatory guidance on this topic.
We are allowing flexibility in the plan eligibility definition as long as premium payments continue on the same basis as they currently do.
Q: Can employers waive their current new hire waiting period during this time?
A: We are allowing employers to make contract changes to shorten waiting periods (30 day change limit) with an immediate effective date for their entire existing employee population. For example, an employee hired Feb 1 with a typical 90 day waiting period could be changed to a 60 day waiting period, making the employee effective April 1. If a group changes its waiting period during this time, that change will remain in place for the rest of the policy year.
Q: If employees are being furloughed or not working actively, does the employee fall under the rehire clause?
A: We’re allowing flexibility in the plan eligibility definition as long as premium payments continue on the same basis as they currently do. Thus, the rehire clause wouldn’t apply because those employees are still employed and on the plan.
Q: How will waiting periods be treated for employees who were terminated and are coming back to work after the COVID-19 pandemic ends?
A: Those employees would fall under the rehire provision and would be subject to any waiting period under that provision of the plan. Employers can shorten their waiting periods (see question above). Additionally, employers can change their rehire waiting period to “date of hire” or “no waiting period.” The ability to do this already exists in their contracts.
Q: Are you maintaining the practice of underwriting if there is more than a 10 percent enrollment change?
A: For population changes above 10 percent, employers should expect to go through underwriting. We will continue to evaluate for flexibility.
Premium Billing
Q: Are you offering payment options for employers experiencing financial hardship during this time?
A: All policies have existing premium billing grace periods which continue to apply and provide some flexibility. We are aware that there may be governmental activity to put financial supports for businesses in place as well. Employers should speak to their legal counsel or trade groups to learn more.
Q: What happens if employers can’t contribute at least 50 percent toward the employee premium right now; would that make the group ineligible?
A: A group that does not contribute a minimum of 50 percent for its leanest plan would not be eligible for renewal.
Q: When would cancellation for non-payment occur?
A: Health plan contract termination would occur in the month following the end of the grace period.
Q: Can HealthPartners process automatic bank drafts at this time?
A: Yes. We allow automatic bank drafts or electronic fund transfers as part of our e-billing options. There are no changes for groups using e-billing. Groups that would like to move to e-billing should alert their sales representatives.
COVID-19 Coverage (including telehealth)
Q: Is testing and diagnosis of COVID-19 covered at 100 percent?
A: Yes. Based on the Families First Coronavirus Response Act, we cover any type of provider visit associated with testing for COVID-19 with no member cost sharing, regardless of plan design. This includes care at Virtuwell, Doctor on Demand, Teledoc and all e-care visits.
Q: If a COVID-19 test isn’t administered, how will the visit be covered?
A: When a test is administered, the cost of the test and associated visit is covered 100 percent. If a member seeks care but does not get a COVID-19 test, the visit will follow current plan coverage and cost sharing.
Q: Will you cover virtual visits at 100 percent for COVID-19 symptoms?
A: Yes. Based on the Families First Coronavirus Response Act, we cover any type of provider visit associated with testing for COVID-19 with no member cost sharing, regardless of plan design. This includes care at Virtuwell, Doctor on Demand, Teledoc and all e-care visits.
Q: Some providers are referring patients to virtual visits for non-COVID-19 situations. Are you covering all virtual visits at 100 percent?
A: Virtual visits for services not related to COVID-19 testing and diagnosis, including physical therapy, speech therapy and occupational therapy, follow current plan coverage and cost sharing.
Q: Are telemedicine options for members expanded?
A: Members have several coverage options under their plan including, virtuwell and Doctor on Demand. Additionally, many providers are moving to virtual visits given the current COVID-19 environment and we have the ability pay those providers as telemedicine visits.
Self-Insured Groups
Q: Can self-insured plans opt out from 100 percent coverage of COVID-19 testing and diagnosis?
A: No. The Families First Coronavirus Response Act, signed into law on Wednesday, March 18, included the provision that self-insured groups cannot opt out of this coverage.
Q: Is there any effect on stop loss coverage due to COVID-19?
A: Stop loss claims will continue to be processed as they are currently, per the stop loss contract. Claims for members allowed under the flexibility in eligibility definitions for furloughed employees will be considered eligible expenses for stop loss.
Q: Does claims incurred by employees still eligible on plan but not actively at work meter towards stop loss?
A: If a member remains eligible under the self-insured plan from the employer, then any claims for that member will be eligible under stop loss so long as premium payments continue uninterrupted.
Q: What limitations, if any, will be applied for COVID-19 claims under the stop loss contract terms?
A: COVID -19 claims that are eligible under the underlying policy will be eligible expenses for stop loss.
Q: What additional claims expense do you expect COVID-19 will result in?
A: At this time, we are unsure of the cost impact of COVID-19.
Q: If an employer terminates a certain percentage of their workforce, will the minimum attachment points continue to apply?
A: Due to the lag between the date a medical service is incurred and the date that service is paid, the claims incurred by the covered population this month, for example, will not be the claims paid this month. As a result, the minimum attachment point will continue to be applied.
Q: If a group has significant layoffs due to this situation, will HealthPartners consider changing the specific deductible mid-year?
A: Mid-year changes in the specific stop-loss level would be considered on a case-by-case basis.
Other Topics
Q: Are you still paying claims?
A: Yes, claims administration is fully operational. The vast majority of claims are submitted electronically and auto-adjudicated. Our team is working to handle any claims that need to be addressed manually.
Q: Is Member Services still available and staffed?
A: Yes, Member Services is fully operational. Our call volumes are steady and we are actively working to serve our members.
Q: Can employees change their FSA amounts due to COVID-19?
A: We are not aware of any guidance on this. We are monitoring for any flexibility that might become available. Helpful tools for FSA users include Using Your HSA Plan and the FSA/HSA Health Shopper.
Q: What EAP services are you providing?
A: HealthPartners presented a webinar on COVID-19 on Friday, March 20 for EAP customers. It was recorded and can be watched here. You can also go to hpeap.com and find it under Online Seminars. The session offered tips for reducing stress, working from home (especially if you have kids at home with you), and maintaining perspective during this unprecedented time.
Q: What recourse do employers have if an employee shows up to work displaying COVID-19 symptoms? Can they require an employee to self-quarantine? How long does the employee need to be symptom free before returning to work?
A: These situations are unique to each employer. We cannot provide advice on this matter. Employers should speak to their own legal counsel, trade groups or consult regulatory guidance. We also encourage you to check the CDC’s Resources for Businesses and Employers for recommendations.
Q: What COVID-19 symptoms should we be concerned about with employees?
Q: Any additional free services available to organizations and their employees during this time?
A: We have many resources available for HealthPartners members by logging into their web account. We will also be communicating additional wellness resources for members over the next week.
Q: Are you making any changes that will eliminate required paperwork for employers or brokers?
A: While we are making as many accommodations as possible during this time, we do need to maintain the appropriate level of documentation. Thus we’re unable to make changes to this at this time.
Q: Will HealthPartners be revising its plan documents to accommodate benefit changes?
A: We do not recommend plan changes at this time given the temporary nature of these extraordinary circumstances.
Q: Have any changes been made to extend eligibility/coverage for dependents aging off plans at age 26?
A: No, there has been no state or federal guidance on this. We will continue to monitor this.