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.
Shortcuts and Resources
Frequently Asked Questions
Below are answers to some of the most common questions we’ve received.
Changes in Employee Status and Effect on Coverage
Q: What is the difference between furlough, temporary layoff and permanent layoff?
A: Furlough is a temporary leave of absence or reduction in hours imposed by the employer, typically for business or economic reasons, where employment has not been terminated.
Temporary layoff is a temporary termination of employment with the intent to rehire or recall at some point in the near future (e.g., within 6 months.)
Permanent layoff is a permanent termination of employment with no specific intent to rehire or recall the employee to work. Permanent layoff or termination results in a loss of coverage and a COBRA event or option for individual coverage.
At this time, HealthPartners is not differentiating between furlough and temporary layoff in terms of applying contract eligibility provisions. Employees and their dependents who are on furlough or temporarily laid off will remain eligible for coverage as long as the employer contribution and the premium payments continue on the same basis as they previously did (i.e., no change in the cost share and premiums remitted by employers via the normal billing process.)
Q: If employees are still employed but working less hours or not actively working at this time, are they eligible to stay on the plan?
A: Yes. 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 above.
Q: If employees are laid off, would they be eligible to stay on the plan or should they be changed to COBRA status?
A: If an employee is laid off with the intent to bring them back in the future, our expanded definitions of eligibility as outlined above would apply, assuming premium payments are made as before.
If your group is permanently terminating or laying off employees, they should go through your normal termination process and the employee should be offered COBRA.
Individuals who lose coverage and do not choose COBRA may obtain coverage on the Individual market, and may be subsidy-eligible based on income.
In Minnesota, MNSure HealthPartners individual plans are available to residents living in the Twin Cities, western MN and St. Cloud areas through MNSure or directly from HealthPartners by calling (enter individual sales number here) on healthpartners.com.
Wisconsin, Iowa, South Dakota and North Dakota utilize the federal exchange and further information is available at Heatlhcare.gov. Loss of job based coverage is considered an event that allows a person to seek new coverage under a Special Enrollment Period.
Q: When would COBRA apply if furloughed employees are not rehired?
A: The presumption with a furloughed employee under our current, more flexible definition of an eligible employee during this COVID-19 pandemic is that the furloughed employee is still receiving coverage under the same premium payment arrangement with the employer as previously was occurring. If the employer subsequently determines that the employee will not be rehired, and ultimately stops paying premium, coverage is terminated at the end of the month in which premium was received, and the normal termination process would start, with all of the typical COBRA rights and obligations.
Q: Will a furloughed employee count towards group size requirement??
A: Yes. During this unprecedented time, we will count furloughed employees for group size determination so long as premium payments continue on the same basis as they currently do.
Q: Can groups change the amount of premium paid by the employer versus the 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% and the employee contributes 25%, those should remain the same. If a group wants to continue coverage but change the contribution percentages, we will review on a case by case basis to determine how the proposed change may impact the underlying risk of the group.
Q: Can employers keep their policies active if there are no employees employed?
A: No. 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. Employers should speak to their own legal counsel, trade groups or consult regulatory guidance on this topic.
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: Can employers waive their current new hire waiting period during this time?
A: Yes. We are allowing employers to continue making contract changes to shorten waiting periods. Making a change in eligibility to date of hire will have an effective date of the first of the month following receipt of the request. All other changes to waiting periods may be made effective the first of the month the request is received if they want to allow employees currently in their waiting period to be eligible for coverage within a shorter period of time. If a group changes its waiting period during this time, that change will remain in place for the rest of the policy year.
Q: Can an employer add a rehire waiting period that is different from the new hire waiting period provision?
A: Yes. A rehire provision may have a different waiting period from that of new hires, as long as you treat all similarly situated employees equally.
Q: If the waiting period changes now, does it remain that way for the rest of the plan year?
A: Yes. In general, these changes should remain in place for the rest of the policy year. To avoid unnecessary administrative costs and adverse selection, only one request per contract year for a waiting period change off-cycle is allowed. We will review other requests on a case by case basis, and only in unusual circumstances would an additional change be considered.
Q: If employees are being furloughed or not actively working but remain on the plan, does the employee fall under the rehire clause?
A: No. Since we’re allowing flexibility in the plan’s eligibility definition, as long as premium payments continue on the same basis as they currently do, the rehire clause wouldn’t apply because those employees are still considered eligible 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 the rehire 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.”
Q: Are you maintaining the practice of underwriting if there is more than a 10 percent enrollment change?
A: Yes. For population changes above 10%, employers should expect to be reviewed via the normal underwriting process. We will be as flexible as we can assuming the underlying risk has not substantially changed. But if the risk has substantially changed, we reserve the right to adjust premiums accordingly.
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. The federal and state governments are providing financial support in the form of loans that can be forgiven (e.g., the Paycheck Protection Program.) These programs can be used for eligible business expenses like payroll and health insurance premiums. Employers should speak to their legal counsel or trade groups to learn more.
For December 2020 small and large fully insured groups in IA, MN and WI will receive a 25% premium credit for each member on their plan in December. If the group terminates their coverage prior to December 1, 2020, they will not be eligible for the credit.
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: What is a COVID-10 diagnostic test?
A: A diagnostic test is used to determine if a person currently has COVID-19. It is done by testing a sample of the mucus from a person’s nose or throat or a sample of a person’s saliva to determine if that person has an active infection of the SARS-CoV-2 virus, which is the virus that causes COVID-19. There are several different types of diagnostic tests, including “PCR” and “antigen” tests.
Q: What is a COVID-19 antibody test (also sometimes referred to as a serology test)?
A: An antibody or serology test is used to determine if a person has previously had and recovered from COVID-19. It is done by testing a sample of a person’s blood to determine if that person has antibodies to the SARS-CoV-2 virus, which is the virus that causes COVID-19. It is very important to note that a positive result on an antibody test does NOT necessarily mean you are immune to getting COVID-19.
Q: Is diagnostic 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 diagnostic testing for COVID-19 with no member cost sharing, regardless of plan design. This includes care at Virtuwell, Doctor on Demand, Teladoc and all e-care visits.
Q: How will the testing, diagnosis and treatment of COVID-19 be covered?
A: Based on the Families First Coronavirus Response Act, during the Public Health Emergency, HealthPartners plans will cover COVID-19 tests and any associated provider visit, including telehealth visits, with no member cost sharing. This is for all plan designs, including HSA-qualified plans.
The full cost of the testing and the associated diagnostic visit will be covered in instances where a test is administered and/or a primary diagnosis of COVID-19 has been made, HealthPartners will waive member cost sharing for COVID-19 tests and diagnosis-related provider visits. Additionally, the health plan covers medically necessary testing that is used to help determine care or treatment decisions or to inform medical advice specific to the patient. It is determined by the patient’s doctor or other appropriately licensed provider. If a member seeks care and is not tested for COVID-19, the health plan coverage applied for the visit will follow the member’s standard (i.e. non-COVID-19) health plan coverage and cost sharing benefits. The cost of testing for purposes of personal or business travel, employment reasons or public health programs are not covered by your health plan.
For fully insured plans, if a member has received a primary COVID-19 diagnosis AND is receiving care directly related to that COVID-19 diagnosis, HealthPartners is waiving member cost sharing for treatment through December 31, 2021. Self-insured plans have the option to waive member cost sharing for COVID-19 treatment, and each self-insured group will make its own decision. HealthPartners Member Services maintains current information regarding each employer’s decisions relating to coverage of COVID-19 related expenses, and will relay that information to covered members as it is requested.
In the majority of cases, most people are directed to self-care. These members will be told to self-quarantine and contact their provider as needed. Most people will recover without needing additional services.
HealthPartners Care Group provides COVID-19 testing at many locations. Patients must complete a screening and set-up an appointment prior to being tested. More information can be found here.
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: Does HealthPartners cover COVID-19 diagnostic or antibody (serology) tests?
A: During the COVID-19 pandemic, HealthPartners covers antibody tests under appropriate circumstances. The test should be: ordered by a doctor or appropriately licensed provider; for medically necessary purposes; and must use a test that is on the Federal Drug Administration (FDA) Emergency Use Authorization (EUA) list or on a state-approved antibody test list.
Q: Are all antibody tests covered?
A: No, the antibody test performed must be on the Federal Drug Administration (FDA) Emergency Use Authorization (EUA) list or on a state-approved antibody test list in order to be covered.
Q: If someone tests positive for COVID-19, how will the treatment be covered?
A: If a member has tested positive for COVID-19 AND is receiving medically necessary and appropriate care directly related to the COVID-19 diagnosis, all HealthPartners members on fully insured plans will have their member cost sharing waived for that treatment when a primary diagnosis code of COVID-19 is billed by the provider. This is in effect until December 31st, 2021.
For our self-insured customers, it is up to the employer to determine how they want to cover COVID-19 treatments.
In all cases, HealthPartners relies on providers to accurately submit claims for testing, diagnosis and treatment of COVID-19.
HealthPartners will work to process claims with information available and will re-process if necessary based on additional information provided. We will continue to monitor this and make necessary changes based on federal regulations.
Q: Are telemedicine options for members expanded?
A: Yes. In many cases, care providers are now providing telemedicine options to their patients. Especially during the crisis, and pursuant to state and federal guidelines and regulations, care that is delivered by telemedicine options will be covered the same as if the care were delivered in person. Also, depending on where they live, members have other coverage options under their plan that may include virtuwell and/or Doctor on Demand.
Q: If a member is seeking COVID-19 care virtually, how will the visit be covered for any of the virtual options available, like CareLine, virtuwell, Doctors on Demand, or an eVisit at a clinic?
A: This varies by which service is used:
- CareLine – all calls to CareLine are free of charge to the member. Nurses will triage all calls based upon medically accepted protocols. If a CareLine nurse recommends the patient seek additional services from their provider, the actual claim for any COVID-19 testing would be handled as outlined above.
- Doctor on Demand – if a member uses Doctor on Demand, the visit will be covered at 100% (i.e., waive member cost sharing) if there is a COVID-19 test ordered and performed. eVisit with provider – many clinics have added eVisits for their patients. All eVisits are covered as per the plan’s schedule of benefits (varies by plan.) Again, the only time the member cost share is waived (i.e., the visit is covered at 100%) would be for those situations in which a test was subsequently ordered and performed.
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 March 18, included the provision that self-insured groups cannot opt out of this coverage. The same criteria outlined above apply.
Q: Is there any effect on stop loss coverage due to COVID-19?
A: No. 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: Do 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: All 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: While this situation is quite fluid, HealthPartners' initial estimate is for a cost impact in the range of .1% to .6% for self-insured employers covering testing and treatment of COVID-19 cost at 100%. These results will vary based on a number of factors including the severity of the pandemic, employer specific demographic with older populations tending to have higher cost than younger population, and benefit plan design with higher deductible plan having higher cost impact than low deductible plans. This estimate is subject to considerable change as the pandemic progresses and more information becomes known.
Q: If an employer terminates a certain percentage of their workforce, will the minimum aggregate attachment points continue to apply?
A: Yes. 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. Please work with your account manager if interested.
Q: Will HealthPartners adjust expected claims rates for self-insured groups who choose to cover treatment for COVID-19 at no cost sharing??
A: We will not change the expected claims rates if a self-insured group chooses to cover COVID-19 treatment with no cost sharing.
Other Topics
Q: How will COVID-19 vaccines be covered by HealthPartners?
A: All non-grandfathered private health plans (individual, small group, large group and group health plans) must cover certain preventive services without cost-sharing. The CARES Act required that COVID-19 vaccines (or other items or services to prevent or mitigate COVID-19) must be covered with no cost-sharing within 15 business days of their receiving appropriate recommendation by the United States Preventive Services Task Force (USPTSF) or Advisory Committee on Immunization Practices (ACIP).
Q: Can employees change their health FSA amounts due to COVID-19?
A: Due to the impact of the COVID-19 outbreak, the IRS has issued new guidance allowing employees to make changes to medical elections and flexible spending accounts (FSA).
With this guidance, you may be eligible to make changes such as adding or deleting dependents on your medical plan or making contribution changes to your FSA accounts going forward. This is a unique exception for 2020. Typically, mid-year changes are only allowed within 31 days of a qualified status change such as marriage, birth of a child, divorce, etc.
Q: Are mid-year contribution changes allowed on a dependent care account?
A: For qualifying events, employees do have the option to make mid-year contribution changes to their Dependent Care Account. Contributions can be decreased or increased up to the allowable IRS maximum. Employees may also elect to completely discontinue contributions to their account. The following are examples of the most common Dependent Care Account qualifying events occurring due to COVID-19:
- Change in daycare provider
- Change in the employment status of employee or employee’s spouse(e.g. changing from full-time to part time, or job loss)
- Change in cost or coverage of dependent care (e.g. child-care center charges a different rate or temporary closes).
Please refer to your plan document for a complete list of qualifying events and effective date of mid-year contribution changes.
Q: Are over-the-counter (OTC) drugs, medicines and other products eligible for reimbursement on CDHP accounts without the need for a prescription due to the CARES Act?
A: Yes. With the passage of the Coronavirus Aid, Relief and Economic Security (CARES) Act, the Federal government reinstated coverage of over-the-counter (OTC) products as eligible for reimbursement on CDHP accounts without the need for a prescription. This change is effective for expenses incurred on or after January 1, 2020. The law applies to the FSAs and HRAs administered by HealthPartners, and also to HSAs. The law also expanded the definition of qualified OTC items to include menstrual care products.
While merchants are working to update their systems to accommodate this change to recognize OTC products as qualified expenses, we anticipate members may experience inconsistences among retailers being able to automatically substantiate these purchases as eligible claims when using a debit card. If this occurs, members can submit their claims for the purchase using the myHP mobile app, online using their HealthPartners account, or manually.
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.
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, there has been no state or federal direction around this issue thus far, and therefore we need to maintain the appropriate level of documentation as required under current statutes.
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.
Q: Can an employer make off-cycle benefit changes to their medical and/or dental plans?
A: We will allow off-cycle plan changes for both medical and dental groups to a leaner plan. No retroactive plan changes will be allowed.
Criteria:
- We must receive the request in writing prior to the first of the month. The change will go into effect the first of the month following the request. No retro changes will be allowed.
- The group can change to a leaner plan only; they can’t move to a richer plan design.
- The group needs to keep the same benefit administration year: plan year to plan year, and calendar to calendar year.
- The group will keep the same renewal date.
- The group will pay as billed and would receive a credit for any plan changes on an upcoming bill. (It may be the next bill depending on the timing.)
- Claims: If the group is moving to a higher deductible, claims will not be reprocessed.
- Example: January group making a plan change on 5/1. From 1/1/2020 – 4/30/2020, they would be on Plan A and all the meters would be counting towards Plan A. On 5/1/2020, with the plan change, they would be put into Plan B. All the meters would transfer over but the claims from 1/1/2020 – 4/30/2020 are not reprocessed. If the member has additional claims after 5/1, they will be responsible for meeting the new deductible/OOP but their meters would carry over.
- Large groups: Same criteria applies as above. Sales should work with your underwriter on rates for alternate plan.