COVID-19 Update: Washington Small Group Eligibility and Continuation of Coverage Contract Provisions

The information below is specific to the Premera Small Group contract and may not be applicable to fully insured 51+ plans.

Premera and Connexion are here to help support our small group employer customers and producers, and to keep our communities safe during this time period. We understand there will be questions regarding health plans including covered services as well as continuation of coverage provisions should an employee no longer meet the eligibility provisions established by the employer, including the number of hours worked to remain on the plan.

60 Day Premium Grace Period

As of March 17, 2020, Premera extended the 30-day premium grace period to 60 days for insured groups. This extended grace period is in place to ensure employees are continuing to receive the care and medications they need during this critical time.

There are restrictions that generally do not allow carriers to offer premium discounts or waivers to employers. However, in Washington state, the Governor’s Office has compiled this partial list of resources to support economic retention and recovery, including Economic Injury Disaster Loans, tax filing extensions, and employer and worker assistance. For more information, click here.

Benefits Available for Testing and Treatment

On March 3, 2020 the U.S. Department of Health and Human Services (HHS) announced the COVID-19 will be covered as an Essential Health Benefit. The Washington Office of the Insurance Commissioner (OIC) also issued an emergency order March 5th requiring carriers to cover FDA-authorized COVID-19 testing with no prior authorization or cost share to the member. This includes testing and any related provider visits and applies to all plans, including qualified High Deductible Health Plans, regardless of where the member resides.

Treatment and/or hospitalization for COVID-19 is covered under the standard cost shares of the plan the member is enrolled on.

In addition, the prescription drug benefit has been revised to remove edits for refilling prescription too soon to allow members to have an adequate amount of necessary prescription drugs available to them.

Continuation of Coverage

The member benefit booklet includes information on eligibility and continuation of coverage provisions including Leave of Absence, Continuation of Coverage, and COBRA.  Employers and members can access copies of their benefit booklet through their respective portals on premera.com or by entering their group number using the following link:

https://www.premera.com/wa/visitor/shop-for-plans/group-booklets/

The Leave of Absence provision allows for a subscriber and enrolled dependents to remain enrolled for up to 90 days provided they are granted a leave of absence and premium continues to be paid. The contract does not state who has to pay that premium so it can be either employer or employee paid.  Here is the content:

If an employee is no longer considered eligible for the plan, they must be offered the ability to continue coverage.  Employers with less than 20 employees can offer their employees up to three months of coverage through the Three Month Continuation of Coverage provision in the contract. The contract does not state who pays the premium, only that it be submitted with regular employers premium payment:

Employers with 20 or more employees are required by federal law to offer 18 to 36 months of continued coverage through COBRA.

In response to the COVID-19 outbreak, The Washington Health Benefit Exchange is offering a special Open Enrollment Period which may also provide coverage on an individual basis with possible premium subsidies:

https://www.wahbexchange.org/

Rehire Provisions

If an employee is rehired within 6 months of coverage ending, they can be re-enrolled on the plan without having to re-satisfy the probationary period established by the employer. Members re-enrolled on the same policy within the same calendar year will have any deductible and out of pocket expenses credited when they are re-enrolled.

Resources and Information

Premera is providing information directly to producers and employer group administrators through the Producer and Employer Bulletins. These updates are also available at premera.com using the following links:

https://www.premera.com/wa/employer/
https://www.premera.com/wa/producer/news/


If you have any questions on our small group plans and processes, please contact Connexion’s PBC WA Small Group Team