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COVID-19 Vaccine Information

We will provide coverage for COVID-19 vaccines in accordance with applicable state and federal guidance. Because no FDA-approved vaccine is available, much is still unknown and we continue to monitor the situation as it develops.

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. 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.

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 ends 60 days after the COVID-19 National Emergency has been lifted. The federal government will decide when the National Emergency has ended.

How will LBS be handling the regulatory changes identified above?

LBS is working on an operational plan to automatically extend all applicable deadlines and 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, through the National Emergency.

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 the form 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.
Reimbursement Accounts

LBS will extend the number of runout days to allow for the extension throughout the National State of Emergency.  This change will apply to the following plans:

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

If your deadline to file an appeal was 3/1/2020 or after, LBS will extend the time allowed to file the appeal.

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 base off of the extensions of the National State of Emergency.

Other

Form 5500 filings that would otherwise be due on or after April 1 and before July 15, 2020, are now due on July 15, 2020.

For more detailed information, please visit the Department of Labor’s website or consult your own employee benefits counsel.

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.

Subsidizing COBRA Premiums for Those Impacted by COVID-19

We understand this is a difficult time for many, including those whose employment has been impacted by the COVID-19 pandemic. To help alleviate some of the concern and financial stress in these circumstances, some groups may decide to subsidize the COBRA premiums for those employees. In these instances, LBS will set the qualified beneficiary up with a subsidy.

For groups that are established with a remittance to the carrier, the subsidy will be applied to the member, and LBS will pay the carrier directly the subsidized portion of the premium. The group will receive a report and be responsible to pay LBS directly for the subsidized portion of the premium that has been advanced and paid to the carrier. For groups that are established with a remittance back to the group, the subsidy will be applied to the member. It will be the group’s responsibility to transmit all premiums to the applicable carrier.

Please Note: Subsidizing COBRA premiums may have implications for your employees. We strongly urge you to consult an employee attorney before making the decision to subsidize COBRA premiums.

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.

As the COBRA administrator, LBS bills the COBRA member directly. Will there be an option for the group to be billed if the group chooses to pay either all or part of the COBRA premium?

Subsidizing COBRA premiums may have implications for your employees.  We strongly urge you to consult an employee attorney before making the decision to subsidize COBRA premiums.

Should a group elect to pursue a premium subsidy, they can contact their dedicated LBS COBRA and Premium Billing representative.  If the LBS contact is not known, email LBSTeamPurple@lifetimebenefitsolutions.com.

For any member that a group wishes to subsidize a premium, they should provide the following:

  1. Member(s) name
  2. Last 4 digits of the SS#
  3. Benefit/plan being subsidized
  4. Duration of subsidy
  5. Amount of subsidy to apply to the member.

Please note:

  • Full dollar or percentages can be utilized
  • If multiple members are to be included, spreadsheet summary is acceptable, we do not need individual emails per member.

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.

If a company pays for part of the deductible on an HRA do they have to pay for the COBRA HRA portion as well?

No, the member is typically required to pay their HRA COBRA premium. It can be subsidized by the employer as mentioned above.
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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