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COVID-19 Vaccine Information

Will members have to pay to get the vaccine?

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.

When can members get vaccinated?

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:

  • Long term care residents
  • EMS workers
  • Essential workers
  • General population

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.

Where can members get vaccinated?

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.

Who can members receive a vaccine from?

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.

Departments of Labor and Treasury COVID-19 Regulatory Changes

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:

What are the regulatory changes?

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.

What are the time periods for continuation of coverage with the regulatory change?

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.

Who do the extensions apply to?

The extensions apply to employee benefit plans, employers, members, and beneficiaries subject to the Employee Retirement Income Security Act (ERISA).

Are the extensions retroactive and when do they end?

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.

Are there COBRA subsidies available?

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:

  • Had a reduction of hours or involuntary termination, and
  • Are currently enrolled in COBRA, or
  • Declined or did not elect COBRA previously but are still within their COBRA period had they elected COBRA, or
  • Dropped COBRA but would still be within their COBRA period if they had not dropped their COBRA coverage

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

How will LBS be handling the regulatory changes identified above?

LBS will apply the extensions on a member level basis in order to abide by the new regulatory requirements.
COBRA

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:

  • 30 or 60-day deadline to notify a plan of a COBRA qualifying event
  • 14-day deadline for providing COBRA election notices
  • 60-day COBRA Election Period
  • Initial 45-day premium payment due date
  • Grace period for premium payment due date
  • 60-day deadline for individuals to notify a plan of a disability

Does the DOL guidance impact other premium billing arrangements, such as retiree billing?

The regulation does not apply to other premium billing arrangements outside of COBRA.

Are all COBRA lines subject to extension (medical, dental, vision, etc.)?

All COBRA-eligible plans are subject to extension except state mini-COBRA (fewer than 20 employees).

How will COBRA billing operate considering these extensions?

The initial and subsequent billing will be processed as usual. The due dates within billing documents will be extended based on regulatory guidance. There will be an attachment included in member communications with extension information. Additionally, a monthly payment reminder will be issued for members with past due premiums.

How does a member notify LBS if they want to voluntarily terminate COBRA coverage?

LBS will only terminate coverage during the National Emergency upon member written request. Members should email a completed Member Termination Request form to LBSMember@lifetimebenefitsolutions.com or mail directly to Lifetime Benefit Solutions, P.O. Box 332, Liverpool, NY 13088.

Can partial payment be made?

Yes, partial payment can be made. However, full premium payment due must be received on or before the extended deadline or coverage will be terminated retroactively.

How will claims be impacted if a member has not paid the required premium for coverage?

Each respective insurance provider will have their own policy and procedure with respect to claims processing. A member cannot be denied coverage; however, the insurance provider is not obligated to pay for the service until the premium is satisfied. The member may be required to pay out of pocket and file for reimbursement, or the insurer may pay the claim and request reimbursement from the member or provider.

Are there alternative options to COBRA?

Healthcare coverage for members and their families is important and we understand that the associated cost can be a financial challenge. Opportunities may be available for low-cost and/or subsidized plans on the individual market rather than through COBRA. We encourage members to visit the Healthcare Insurance Marketplace at www.HealthCare.gov or call 1-800-318-2596 to consider which option is most suitable and affordable for them.
Reimbursement Accounts

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:

  • Health Flexible Spending Accounts
  • Health Reimbursement Accounts
  • Limited Purpose Flexible Spending Accounts

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.

TPA

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.

COBRA Resources for Our Valued Groups and Brokers

For those groups who offer COBRA, all COBRA processing will be continuing as usualTo 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:

  • Via regularly scheduled file feeds directly from the group
  • Via the COBRA employer portal on LifetimeBenefitSolutions.com
  • Via email from the group administrator


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:

  • Paycheck Protection Program - Assistance to cover the cost of retaining employees
  • Emergency Economic Injury Grant - Grants to help cover your business now
  • Small Business Debt Relief Program - Relief from keeping up with payments on your current or potential SBA loan

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.

COBRA and COVID-19: Frequently Asked Questions

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.

If a group goes out of business, will COBRA coverage be offered to its members?

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.

If a company lays off staff or reduces hours due to COVID-19, resulting in the group not meeting subscriber eligibility guidelines, laws or regulations, what is LBS’ position at this time regarding those circumstances?

We are actively working with groups who are experiencing changes to their eligibility in order to accommodate the coverage needs of our customers and community. Ultimately, the decision will be dictated by each specific carrier.

Does LBS have the capacity to handle an influx of COBRA enrollments, notices and new participants?

Yes, LBS has secured additional resources to process the anticipated influx of COBRA activity.

What forms of payment are accepted for COBRA premium payments?

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.

Can we differentiate traditional COBRA members from COVID-19 COBRA members?

Yes, LBS can track COVID-related COBRA events from traditional COBRA events. Members should be reported to LBS through the normal input channel. There will be an additional group and/or broker requirement to email a member roster for those where COVID-19 tracking is required to LBSTeamPurple@lifetimebenefitsolutions.com.

If COBRA is required and the group uses LBS as their COBRA administrator, will there be a change in how quickly the COBRA enrollment packet is mailed?

Initial member notifications are processed automatically once loaded into the system. We do not anticipate any delays in mailing enrollment paperwork currently. There is a possibility that individual carriers may experience delays affecting coverage changes due to anticipated increases in volume.
Employer COBRA Resources

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.

Legislative Changes: Defined Contribution Plans

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:

  • Diagnosed with COVID-19 (Coronavirus) by a test approved by the CDC
  • Individuals whose spouse dependent is diagnosed with an approved test
  • Experiences adverse financial consequences as a result of the individual, individual’s spouse, or a member of the individual’s household (this is, someone who shares the individual’s principal residence), including:
    • (a) being quarantined, being laid off or furloughed, or having his/her work hours reduced due to COVID-19
    • (b) being unable to work due to lack of child care due to COVID-19
    • (c) the closing or reduction in hours of a business owned or operated by the individual due to COVID-19
    • (d) having pay or self-employment income reduced due to COVID-19
    • (e) having a job offer rescinded or start date for a job delayed due to COVID-19
    • or (f) other factors as may be subsequently determined and announced by the Treasury.

    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:

  • Limited to $100,000 per tax year, aggregated across all plans of the employer or controlled group
  • Eligible to be indirectly rolled into an IRA or employer plan within 3 years from the date the distribution is taken
  • Not subject to 20% mandatory tax withholding upon distribution
  • Exempt from 10% early withdrawal penalty generally applicable to distributions made to participants who are younger than 59-1/2
  • Amounts not indirectly rolled into an IRA or employer plan are included in gross taxable income, ratably, over 3 tax years (beginning with the tax year of the distribution), unless the participant elects to include all amounts in a single tax year

Plan Loans

Plan loans to eligible affected participants (defined above) are subject to the following changes:

  • Increases the maximum dollar amount available for a loan from $50,000 to $100,000
  • Increases the maximum percentage available for a loan from a participant’s vested benefit from half the value to the entire vested value in the plan
  • If loan is taken on or before December 31, 2020, repayments may be delayed for one year from the original date

Required Minimum Distribution Changes

Required Minimum Distributions (RMD) delayed as follows:

  • One-year delay in RMDs for defined contributions plans, IRAs and section 457 plans
  • Applies to 2019 RMDs that would otherwise need to be taken by 4/1/2020 and to 2020 RMDs
  • Allows amounts subject to the RMD rules in 2020 already taken to be rolled into a retirement arrangement
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