Carrier Grace Periods and Relaxed Eligibility

Insurance Commission Ricardo Lara issued a Notice requesting that all insurance companies provide their policyholders with at least a 60-day grace period to pay insurance premiums. The Commission’s requests was to ensure policies are not cancelled for nonpayment of premium due to the Coronavirus (COVID-19) public health emergency. Groups are required to submit payment by the due date shown on their bill. If a group misses their due date, they have up until the standard grace period to make a payment before coverage is cancelled. The standard grace period begins the day after the missed due date. Carriers are reviewing their policies to determine if/how they can assist their employer groups with making payments during this difficult time.

 

Extended Premium Grace Periods

Carrier

Extended Premium Grace Periods: California Insurance Commissioner Calls for 60-Day Insurance Premium Grace Period

Standard Grace Period
Aetna Per the Insurance Commission notice, Aetna will support a 60-day grace period for small groups. Large Group: requests will be reviewed on a case-by-case basis - Contact Group's Account Manager for assistance. *NEW* May pay true premium. Employers should indicate terminated employees on the bill, then review the next bill to ensure they are removed. 31 days
Anthem Blue Cross A general policy has not been put into place but requests will be reviewed on a case-by-case basis - Contact Group's Account Manager for assistance. The standard grace period is 31 days. 31 days
Blue Shield of California A general policy has not been put into place but requests will be reviewed on a case-by-case basis. If a group has determined they will not be able to pay on time they should contact the Billing Team (800-325-5166). 30 days
Cal Choice Requests will be reviewed on a case-by-case basis. Contact the group Account Manager or Customer Service for assistance. 30 days
Cigna Clients headquartered in CA, are able to a 60 day grace period if they need it and let us know. Cigna would then request from Finance that the client wants this extended grace period. The Financial/Billing Analyst for the client would note this in the client’s file as to when to expect premium. Then she/he would manually stop their ACH payment. The client would then be responsible for paying a double payment for the month that has the extension. -
Guardian Guardian is allowing a 60 day grace period however claims will not be paid until premium is paid. (Exceptions are possible on a case-by-case basis - If needed, contact Client Account Manager) 31 days
The Hartford (until June 1st 2020) suspending policy cancellations due to non-payment of premiums for payments due for February, March and April 2020. -
Kaiser Permanente Kaiser allowing a 60-day grace period before suspending coverage. 30 days
Lincoln 60-day grace period (or longer if required by law) through September 30, 2020. 30 days
MetLife MetLife will support a 60-day grace period beginning 3/1/20 through when COVID-19 is deemed to be over. Customers with fully insured dental PPO plans will receive a premium credit on a future bill in the amount of 25% for the months of April and May, 2020. 30 days
Mutual of Omaha - -
Principal Principal is allowing for the 60-day grace period 30 days
Prudential Effective immediately, we will extend premium grace periods on all coverages for an additional 90 days** from what is currently allowed in the contract. Premium should be paid as billed, where possible. -
Reliance Reliance will work in good faith with all clients impacted to extend reasonable accommodation with regard to timely payment of premium.  
The Standard Regarding guidance on premium/benefits- we are able to extend their grace period an additional 30 days to their existing grace period for payments due from now through June. Please have the group send us an email requesting the extension and we will take the necessary steps to update our systems. In addition, due to businesses closing and individuals having limited access to mail due to COVID-19 we are extending the deadline for Port/Conversion by 30 days if impacted customers ask for it. They can email their applications to cbt@standard.com and include in the email that they are requesting the extension. 30 days
Sun Life The earlier of: 90 days or the end of the period when a person is 30 days
Sutter Health Plus Sutter Health Plus has not changed its billing process due to this situation. We currently offer small employer groups a minimum of a 30-day grace period for premium payments. We will continue to monitor the situation and guidance from the DMHC. 30 days
UnitedHealthcare A general policy has not been put into place but requests will be reviewed on a case-by-case basis - Contact Group's Account Manager for assistance. 30 days
UNUM If an employer anticipates having any issues with being able to remit premiums due to the circumstances surrounding COVID-19, please contact AskUnum at askunum@unum.com or connect with the groups Billing Coordinator. 30 days

Relaxation of Eligibility

Carrier

Relaxation of Eligibility

Leave of Absence and Layoffs (Furloughs) - Will Carrier allow fully-insured clients to continue to offer benefits to furloughed or with reduced hours due to COVID-19? How Carriers are Handling Rehires Allowing Mid Year Plan Downgrades**
Aetna Aetna is not policing employee eligibility. Decision left to employer as to how they want to handle employee that is no longer meeting the eligibility requirements. Aetna had a Special Enrollment Period(SEP) the first two weeks of April. At this time Aetna is not offering another SEP. Aetna is reviewing each Plan Sponsor’s situation on a case by case basis. Aetna has been making the exception to allow customers to keep their furloughed employees covered through July 31, 2020 as long as they pay their monthly premium. If you have a particular case you are concerned about please reach out to the assigned account manager. Employees rehired within 1 year will not be subject to a waiting period. Deductible credit available. Will be applied as long as the member’s ID number has not changed, and in most cases the ID number does not change for re-hires. Yes, employers may make a one-time "mid-plan year" change to downgrade their plan offerings. Submit through July 31, 2020.
Anthem Blue Cross Anthem will allow members who had previously waived coverage to enroll in a plan through August 1, 2020, even absent a qualifying event. This option is available to both fully insured and self-funded groups, excluding life and disability coverage. Anthem will also allow currently covered employees to switch to a lower priced medical plan when one is offered. This option is available for July 1, 2020 and August 1, 2020 effective dates. This Group Special Enrollment Period will last from June 8, 2020 to July 31, 2020 and is available to both Large and Small groups. Anthem’s requirement for employees to be actively working in order to be eligible for coverage will be relaxed through July 31, 2020 as long as the monthly premium payment is received. Coverage must be offered on a uniform, non-discriminatory basis to all employees and employee premium contributions must be the same or less prior to the layoffs. If employee is rehired within 31 days Coverage will resume with no lapse upon Anthem's receipt of a written request from the employer group. If employee is rehired more than 31 days but not more than 91 days after the termination date Coverage shall restart effective on the rehire date. The rehired employee will not be subject to any applicable group-imposed waiting period and must complete a new Employee Enrollment Application. If employee is rehired more than 91 days (13 weeks) after the termination date The employee is considered a new employee, subject to any applicable group-imposed waiting period and must complete a new Employee Enrollment Application. -
Blue Shield of California Employees could be either furloughed (i.e. not working at all) or working fewer hours than required to qualify for active status (i.e. reduced hours). In either situation, employees Blue Shield coverage will continue through June 30, 2020 as long as premiums are received. Coverage must be offered on a consistent, non-discriminatory basis to all employees, and employee premium contributions must be the same or less as prior to the layoffs, furloughs or reduction of hours. Blue Shield is providing a Special Enrollment Period (SEP) through June 30, 2020 for employees who previously declined coverage for themselves or their dependents. This applies to all fully insured small group (1-100) and large group (101+) employers, as well as MedSupp.

Broker updates | Blue Shield of California
Blue Shield will NOT be allowing a Special Open Enrollment off-anniversary where employees can choose any plan.

Standard rules apply. The waiting period will be waived only if re-hired within 6 months. Blue Shield will allow a one-time buy-down plan change off-cycle for employers and employees to adjust their health plan selection to meet their current needs. April Effective Date Submit through April 15, 2020. May - July Effective Dates Submit through June 30, 2020. All changes must be received are effective 1st of the month after the application received date.
Cal Choice As long as the group and employees are current on their monthly payments, CaliforniaChoice will allow employees that would otherwise have lost eligibility to remain on the plan. COBRA is available to employees where there is an active employer policy.
Click here for FAQs.
Members can remain on the plan, at the employers discretion, as long as premiums are paid. Rehires do not need to serve waiting period if employee
  • Previously completed waiting period
  • Rehired within 6 months of leaving the company
  • Offered the same enrollment options as new hires
 
Cigna Cigna is relaxing the eligibility guidelines for COVID-19 for clients. The Cigna Client Manager would need a direct communication from the client requesting Cigna will continue coverage through May 1, 2020 for employees who were furloughed or had their hours reduced as a result of the pandemic.    
Guardian
  1. The hourly work requirement can be adjusted to 25 hours per week, then anything between 20-24 would require UW approval.
  2. The current contract allows EEs on a LOA or who are laid off to continue their coverage for the remainder of the month in which the leave or layoff occurs plus 1 additional month for the Life/ADD, Accident, and CI plans
  3. An extended leave/layoff provision for additional months can be offered with UW approval and potential rate impact.
Guardian will consider reduced hours/furloughed employees eligible until 6/30/2020 for all lines of coverage except LTD, provided premium is paid by grace period. Employer decision  
Kaiser Permanente As long as the group continues to send them over as active we do not check eligibility. Kaiser will not check/request anything from the group. Kaiser has opened a SEP for those who waived/declined. Deadline to Submit: Submit through April 3, 2020 for an April 1,2020 effective date. Submit between April 4 and April 15, 2020 fora May 1, 2020 effective date. Click here for more information from Kaiser. Regarding to leave of absence and layoffs, it’s up to the group to determine eligibility. If they get laid off they can opt for COBRA. If the group decides to keep them active during furlough that criteria will be determined by the group. Large Group: will allow the group to define the waiting period, as long as the waiting period and employer contribution are consistent for all employees. Small Group: will allow the group to define the waiting period when the employee returns to work, with no minimum, but no greater than 90 days. Kaiser will allow once effective 5/1/20 but all EE's must change plans
Lincoln As long as premium is paid, employees can maintain coverage as though they are at work through September 30, 2020 or in accordance with the continuation provisions in their policy if they are more generous If temporarily laid or of furloughed or on leave or has reduced hours Lincoln will still consider the employee actively at work and eligible for coverages.    
MetLife Group Life, Dental, AD&D, Vision, Accident & Health and Legal: Will allow employees who are furloughed, temporarily laid-off or have reduced hours/salary to continue their coverage for 12 months from the date of the furlough, temporary lay-off or reduced hours/salary. Premiums need to be remitted for coverage to remain active. Group Life: Will allow employees who are furloughed, temporarily laid-off or have reduced hours/salary to continue their coverage for 12 months from the date of the furlough, temporary lay-off or reduced hours/salary. Coverage amounts will not be reduced as a result of temporary salary reductions and will remain in effect just as they were prior to the furlough, temporary lay-off or reduced hours/salary. Accordingly, premium needs to be remitted based on the volume for the regular (non-reduced) coverage amounts. Group Disability: Will allow employees who experience a furlough, temporary lay-off or have reduced hours/salary between March 1, 2020 and May 31, 2020, to continue their coverage for 60 days from the date of the furlough, temporary lay-off, or reduced hours/salary. Coverage amounts will not be reduced as a result of temporary salary reductions and will remain in effect just as they were prior to the furlough, temporary lay-off or reduced hours/salary. Accordingly, premium needs to be remitted based on the volume for the regular (non-reduced)coverage amounts. Employees rehired within 6 months will not be subject to a waiting period  
Mutual of Omaha Effective 3/1/20 - 4/30/20, if an employee's hours fall below the minimum hours worked as defined in the policy, these employees will be treated as eligible for benefits and actively at work, provided premiums continue to be paid for the original amount of prior to the reduction in hours.      
Principal Members can remain on the plan, through May 31, 2020, as long as premiums are paid. Standard practice is to continue coverage until the end of the month. However, if layoffs or furloughs extend into the next month, coverage will continue until the end of that month, provided premiums continue to be paid.   Principal is allowing downgrades
Prudential Effective immediately, we will agree to change the existing reduction in minimum hours provision in our contract from “If you are working reduced hours, for reasons other than disability, and if premium is paid, you will be covered to the end of the month following the month in which your reduced hours begin” to “if you are working reduced hours for reasons other than disability, and if premium is paid, you will be covered to the end of the month following 90 days in which your reduced hours begin”. Effective immediately, we will agree to change the existing Leave and Lay Off Provision in our contract from “to the end of the month following the month that the Leave/Lay Off occurs” to the end of the month following 90 days from the date of a leave/lay off.    
The Standard Group Life, Disability, Supplemental (including Accident, Critical Illness and Hospital Indemnity), Dental and Vision coverage normally ends when an employee loses eligibility because the employee is no longer working the required minimum number of hours. However, as an accommodation to our policyholders during this time of uncertainty, subject to continued payment of premium, these coverages can be continued through June 30, 2020, while employees are not working due to a partial or full furlough or temporary layoff occurring on or after March 1, 2020. Employees furloughed between 3/1/20 and 9/30/20 can stay on benefits for 90 days or through June 30th, whichever is longer.      
Sun Life SunLife is now allowing employees to stay on active benefits for up to 90 days while furloughed. After that they must sign up for COBRA. Continuation of insurance benefits will be allowed due to: Reduction of work hours resulting in an eligible and insured individual becoming ineligible for coverage; Temporary furlough or leave of absence; Temporary layoff; Inability to work regularly scheduled hours due to Quarantine without medical necessity.    
Sutter Health Plus SHP is not offering a special enrollment opportunity at this time. Eligibility is determined by the employer. Sutter Health Plus expects group employers to determine eligibility for coverage for their employees according to the group employer agreement and state and federal law. Does not monitor and will allow the employer to make the determination. pending
UnitedHealthcare *Special Enrollment Opportunity for fully insured Small Business and Key Accounts clients to enroll employees who did not elect coverage for themselves (spouse, children) or waived coverage initially. Enrollment opportunity will extend from March 23, 2020 to April 13, 2020. Effective date is April 1. Through May 31, 2020, UnitedHealthcare is temporarily relaxing its requirement that employees be actively working to be eligible for coverage and will allow you to cover your reduced hour employees, as long as you pay the monthly premium. Please note that you must offer this coverage on a uniform, non-discriminatory basis. UnitedHealthcare’s special open enrollment for fully insured plans was over April 16, 2020. UnitedHealthcare will not provide coverage for new medical enrollments or changes of enrollment other than those related to (1) annual open enrollment, (2) UnitedHealthcare’s Notice of Special COVID-19 Enrollment Opportunity, which is now closed, or (3) a HIPAA qualifying life event. UnitedHealthcare will temporarily allow (through 5/31/2020) benefits to continue as long as the plan sponsor continues to pay the premiums and offers the option to all furloughed employees on an equal basis. All waiting periods are waived for re-hires employees who were terminated due to COVID-19. Deductible credit not available. The deductible will reset to $0 at re-hire enrollment. Employers with multi-option plan designs can temporarily buy down to a leaner plan.
UNUM   Furloughed employees will remain eligible for coverage up to the greater leave of absence term that is in the policy, or 60 days.    
VSP     ER determines eligibilty  


*Keep in mind that under Section 125 all elections have to be made prior to the start of the plan year unless the individual experiences a permitted election event. Failure to adhere to these rules can cause disqualification of the Section 125 plan. Details in the FAST

https://www.theabdteam.com/blog/making-mid-year-exceptions/

** Material modification notices required

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