Please note: Federal guidance effective Jan. 15, 2022 regarding coverage for at home COVID-19 tests pertains to coverage under prescription plans only. Please contact your prescription plan carrier for additional information.
The first quantity of doses for the vaccine have been paid for in advance by the federal government. There will be no cost share for non-grandfathered group members who receive COVID-19 vaccines that are authorized through an emergency use authorization (EUA) and recommended by the Advisory Committee on Immunization Practices (ACIP).
Coverage for the vaccine administration is covered for participating and non-participating providers through the end of the Federal Public Health Emergency.
We are following the federal, state and county distribution plans for the vaccine. The CDC has said the goal is for everyone to be able to easily get a COVID-19 vaccine as soon as large quantities are available; however, not everyone will be able to get vaccinated right away.
The first people to receive the vaccine will be nursing home residents and staff and high-risk hospital workers followed by:
While specific distribution plans are still in development, we encourage members to prepare for a COVID-19 vaccine by consulting with their primary care provider.
Members should refer to the Department of Health’s website to determine where vaccines are available. Please note that based on the distribution plan, not everyone is able to get vaccinated at this time.
We will follow the state vaccine distribution plan and update providers and locations as the Department of Health updates their guidance. Not all providers will be able to receive the vaccine at this time.
On April 28, 2020, the Departments of Labor and Treasury jointly announced regulatory changes due to the impact of the COVID-19 (Coronavirus) pandemic. These regulations are meant to provide relief for members and plan administrators and are effective retroactively to March 1, 2020. Additional regulations were issued February 26, 2021 that further explain how the relief works going forward. Below is additional detail regarding these changes and LBS’s response:
The time frames within which members can submit claims for coverage, elect and pay for COBRA continuation coverage, enroll in group health plan coverage, and file appeals for adverse benefit determinations have been extended beyond the original February 28, 2021 expiration date.
The time periods in which members can elect and pay for COBRA continuation coverage are tolled, or suspended, for one year from the date a member is first eligible or until 60 days after the National Emergency, whichever comes first.
The extensions apply to employee benefit plans, employers, members, and beneficiaries subject to the Employee Retirement Income Security Act (ERISA).
The extensions are retroactive to March 1, 2020 and end either one year from the date a member is first eligible for relief or 60 days after the COVID-19 National Emergency has been lifted, whichever comes first. The federal government will decide when the National Emergency has ended.
On March 11, 2021 the American Rescue Plan Act (ARPA) was passed into law. One of its provisions is a 100% subsidy of COBRA premium payments, including the 2% administrative fee. This subsidy is available April 1, 2021 through September 30, 2021 for qualified beneficiaries and their dependents who are currently eligible for COBRA and who:
Subsidies are available for all types of coverage that are subject to COBRA except Flexible Spending Accounts.
Members will be sent a notice that they may be eligible for the subsidy. Members who are still within their COBRA timeframe and did not elect COBRA initially or have termed their coverage will be sent a new election form. This new election allows them to elect COBRA for the subsidy timeframe (April 1 through September 30). Members are not required to be enrolled in coverage prior to April 1. A member who elects COBRA under this new election period can remain on COBRA after subsidy period ending September 30, 2021 but will be responsible for their own premium payments starting October 1, 2021.
Employers will be able to obtain reimbursement of the subsidy through a tax credit against their quarterly taxes. LBS will have reporting available to assist with the tax credit process.
On April 7, 2021, the DOL published an FAQ on the COBRA subsidies under ARPA
Guidance Overview
Group health, disability, welfare benefit, and retirement plans subject to ERISA must “disregard the period from March 1 until 60 days after the announced end of the National Emergency or such other date as announced by the agencies.”
The time periods in which members can elect and pay for COBRA continuation coverage are tolled, or suspended, for one year from the date a member is first eligible or until 60 days after the National Emergency, whichever comes first.
Key time frames that have been tolled:
Per updated guidelines issued by the Department of Labor and Treasury on February 26, 2021, LBS will extend the number of runout days to file a reimbursement account claim on a member by member basis. Extensions will end 12 months after the end of a member’s plan run out period or 60 days after the end of the National State of Emergency, whichever comes first. This change will apply to the following plans:
If your plan was recently terminated with LBS, the runout days will NOT be extended for that plan unless instructed otherwise. Please contact your administrator directly for more details on these plans.
LBS will extend claims and appeal deadlines based off the extensions of the National State of Emergency.
Please know that we will follow all regulations and guidance, but these changes will impact our internal operational processes and we are working to make the necessary changes.
For those groups who offer COBRA, all COBRA processing will be continuing as usual. To ensure employees receive the necessary paperwork to continue their benefits through COBRA in a timely manner, please submit your new COBRA qualified beneficiary information and/or terminations as you typically have through one of the following methods:
Small Business Administration COVID-19 Guidance and Loan Resources
During these uncertain and challenging times, our Lifetime Benefit Solutions team is here to provide access to resources to help your business and employees. The Small Business Administration (SBA) has programs and initiatives in place as a result of the Coronavirus Aid, Relief and Economic Security (CARES) Act, passed on March 27, 2020 should your business need assistance.
These programs include:
For more information and to learn how to apply for one of these programs and other initiatives that may be able to provide assistance, visit the Small Business Administration’s website.
The COVID-19 situation is rapidly evolving, and LBS is in contact with local, state and federal health and other officials, and is implementing applicable orders, regulations and requirements as they become effective.
The FAQs provided are specific to offering COBRA coverage to your members and any impacts on this benefit due to the COVID-19 pandemic. It is our hope that these circumstances will be temporary, and that businesses will be able to return to normal operations soon. We will update this information as the situation changes.Generally, COBRA coverage is only offered to businesses with an active plan at the carrier. At this time, no changes will be made to the COBRA operations unless specifically instructed by a carrier.
All forms of payment will continue to be accepted. Members can pay via check, through the online portal via recurring ACH, via the online portal via one-time credit card payment* or by calling the dedicated customer service line at (800) 828-0078.
*The third-party vendor we use to process one-time credit card payments charges a $20.00 processing fee per single transaction. However, you can avoid this fee by (1) mailing a physical check, (2) establishing a recurring ACH payment online, or (3) by calling our customer service department at (800) 828-0078. Our dedicated customer service representatives can process a one-time credit card payment for you over the phone at no additional cost.
We are making helpful tools and resources available to our employer groups to assist in processing new qualified beneficiaries for COBRA. If you typically submit employee status changes via the COBRA employer portal on our website or would like to leverage the portal input option, we have step-by-step tutorial videos available in case you need assistance with performing common tasks or actions within the portal.
In light of the growing concerns and financial impacts of COVID-19, government officials continue to consider options to help relieve the financial burden for Americans. LBS is actively monitoring the environment for any changes, and we will continue to share regular updates with you.
Recent legislative changes have been passed that may impact your employees. Defined contribution plans may permit in-service COVID-19 (Coronavirus)-related distributions from a member’s personal vested account balance without regard to the normal withdrawal restrictions.
Eligibility
This relief is offered through December 31, 2020 for individuals either:
A member’s self-certification that he or she satisfies one of the above conditions is sufficient to allow the COVID-19-related withdrawal.
Hardship Distribution Requirements
These distributions are subject to the following requirements:
Plan Loans
Plan loans to eligible affected participants (defined above) are subject to the following changes:
Required Minimum Distribution Changes
Required Minimum Distributions (RMD) delayed as follows: