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COVID19 Communicating Plan Changes

The COVID-19 pandemic initiated many temporary, and some permanent, changes to both benefits and administration of employee benefit plans.  The fast pace of federal legislation, state bulletins and insurance company responses has left little time for plan administrators to address the compliance requirements of these changes.  


Under both ERISA and ACA regulations, plan sponsors and insurers are required to notify members 60 days in advance of any material modification to a benefit mid-year.  Recent guidance regarding the coverage of COVID-19 testing indicates that the Department of Labor (DOL) will afford some leeway in the advance notice.  They further stressed the importance of communicating the changes as soon as possible.


Listed below are a few areas to consider:


New paid leave and EFMLEA rules


  • Have you posted the required model notice released by the DOL? DOL FFCRA Poster


  • Do you have a process in place to accommodate the requests and approvals?  A temporary policy added to your normal leave policies should be considered.


  • Documents regarding the leave must be retained for 4 years.  How will you store data for future reference?


Coverage for COVID-19 testing and treatment


  • Have you communicated the change in benefits to employees?


Coverage for telehealth at no-cost sharing under a HDHP


  • Has the insurance company added or have you amended your plan to allow for the change?


  • Have you communicated the change in benefits to employees?


OTC medications and menstrual products


  • Will your HRA and FSA be amended to allow for coverage?


  • If so, have you updated your plan document?


  • Have you updated plan language to include coverage of these items under your HDHP?


  • Have you communicated the changes to employees?


Waiving eligibility requirements for employees on furlough/layoff to continue coverage


  • Have you communicated your intention of coverage continuation to employees?


  • Do you have a confirmed date for termination of employer-paid coverage and offer of continuation coverage (COBRA)?


  • Has the date been communicated?


For more updates on updating Health Plans for Coronavirus changes, click here. 


Employers should consider the available options and mandated benefits, communicate to employees as soon as practicably reasonable and update all relevant plan documents.  Feel free to reach out to the First Insurance Group team with any questions. 

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