Premiums: Details on payment delays or relief
We understand that these are uncertain times for small businesses and they may choose to make changes to their benefits plan to minimize the financial impact of COVID-19. These are difficult decisions and we are here to help you and your clients navigate through the following options:
• Continuation of benefits through temporary employee layoffs
• Reduction of benefits through plan amendments
• Renewal deferrals for May and June
• Extension of grace period by 30 days
• Temporary suspension of benefits for 60 days
If you have determined that one of the above options is the right solution for your client please contact your Regional Director or Client Manager for more information.
Employees in The Waiting Period: How is this handled?
Employees who have been laid off during their benefit waiting period will not be eligible for extension of benefits since they were never an active employee on the plan. Once they are recalled to work the employer has discretion on waiving the waiting period in full or in part.
Processing Layoffs: Administrative Steps Required
BBD needs to be notified of all layoff situations with confirmation if coverage is being extended or not. If coverage is not being extended, the employee is simply terminated from the plan and can be reinstated once they return to work. This can be done through Nomad by the plan administrators.
If the coverage is to be extended during the layoff period, the client should contact BBD with the following information:
- Employee Name
- Last Day of Work
- Anticipated Return to Work Date – if this is not available due to the current situation, confirmation of how long the extension should continue (30 days, 60 days, etc)
- Benefits to be extended – it is typically an all or nothing situation however as detailed in question #4 below, Empire Life will allow for an extension of the disability benefits. We will need confirmation if the STD/LTD is to be extended during the layoff
- BBD will update each employee account as required
Coverage, by Benefit and Extensions during Layoff
We strongly recommend that plan sponsors maintain coverage for their employees during a temporary layoff and that they seek the professional advice of an employment lawyer before making a decision to terminate benefits for employees during a temporary layoff (see Benefits by Design’s Business Assistance Program).
Plan sponsors should be aware of the potential risks of terminating coverage including:
- No life or disability coverage
- Employees currently out of the country
- Stockpiling of medications prior to termination
Continuation of benefits
For clients who wish to extend benefits to their employees during a temporary layoff the following options are available:
- Option 1: Retain current layoff provision to allow all benefits except disability to be extended for up to 6 months or otherwise stated in the contract.
- Option 2: New option due to COVID-19. Allow short-term and long-term disability benefits to be extended during the layoff period for 3 months and maintain the 6-month maximum for all other benefits. This is being done as a temporary administration practice and no changes to the contract will be made to reflect this change.
Important: The layoff option has to be decided on at the group level. It can differ by class (the group can lay-off employees in one class and not another) but it cannot differ by individual. Layoff extensions of benefits cannot be extended to individuals; it must be the same for the whole group/class.
** Please note that we will follow RAMQ requirements in Quebec.
Collection of premiums
If Plan Sponsors cannot collect employees’ contributions at this time, they can pay the full premium and collect back when Plan members are back at work. This will not affect benefit taxability but the understanding should be that the employees will "pay back" that premium to the employer once they have returned to work and payroll has resumed.
If an employee has the option to continue their coverage but cancels it because they will not contribute their share of the premiums, when they return to work evidence of insurability will be required to be added back to the plan.
Refusal of coverage
As per Empire Life:
In light of the situation, if an employee on lay-off was under undue financial stress and couldn't afford to pay their share of the premium, the employer could pay the premium and collect back from the employee once payroll has resumed. If the employee is adamant that they do not want to continue the benefits they can waive the coverage while on layoff - no Evidence of Insurability is needed. When the employee returns to work, the pre-existing condition clause will not restart.
Please note: we are still waiting for confirmation on the refusal of coverage process from Green Shield. This is yet to be determined. We will pass along an update once we hear back from Green Shield.
Minimum Hours of Work
When looking at employee eligibility, we look at an average over a period of time. There is no need to terminate an employee from the plan if their hours have dropped due to COVID19 as long as the intention is that the employee will return to working the minimum hours once this situation has resolved itself. At this point, Empire will ignore the reduction in hours and continue to base the payment on their regular number of hours, as long as they continue to be working.
Salary Based Benefit Coverage Amounts
When looking at employee eligibility, we look at an average over a period of time. There is no need to terminate an employee from the plan if their hours have dropped due to COVID19 as long as the intention is that the employee will return to working the minimum hours once this situation has resolved itself. At this point, Empire will ignore the reduction in hours and continue to base the payment on their regular number of hours, as long as they continue to be working.
Unless instructed otherwise by plan sponsors, benefits that are salary based will be adjudicated based on the coverage for which the premium is being paid. Employer and employee premium rates will remain unchanged as we are committed to covering the current amounts on record. If plan sponsors want to ensure employees at their reduced hours for a corresponding decrease in benefits they must submit this request. As this is a temporary change to administrative practice, we will not change customers’
Renewal Handling
All Benepac and Benaccount renewals for May 1 and June 1 will be postponed for two months – until July 1, 2020, and August 1, 2020, respectively. All clients with self-funded plan arrangements (ASO and HCSA), will renew as per their renewal date.
If you have a Benepac or Benaccount client who does not want to defer their renewal, please contact your Client Manager.
Health Care
Rx supply amounts
Green Shield Canada (GSC) is working collaboratively with pharmacy organizations, officials, and the Canadian Life and Health Insurance Association to ensure everyone has access to the medication they need. As a result, plan members will see some differences – most significantly, GSC’s 90-day supply requirement for maintenance medications has been reduced to a 30-day supply to help manage an increase in requests to refill medications. When it comes to requesting refills, they have adjusted their standard approach to allow for refills up to 14 days early.
These changes have been made to their Maintenance Day Supply and Fill Too Soon Rules to adjust to the current times.
Maintenance Day Supply
The Maintenance supply rule of filling 90 days has been suspended to allow for 30-day refills where needed.
Fill Too Soon
The fill too soon rule has also now been adjusted to allow for refills earlier than the previous minimum of 80%.
GSC is trying to avoid drug-hoarding and ensure that the Canadian Drug supply remains healthy. The plan is to allow claims to go through when 50% of the prescription is completed for days supply between 1-30, 70% of the way through for days supply between 31-60, and 75% of the way through for days supply between 61-999.
For certain medications with variable use, such as inhalers, it can be difficult to measure a consistent day supply. In the event that someone requires a refill for this type of medication, have them ask their pharmacist to review the day supply, and if necessary they can utilize the resources available on providerConnect.ca to assist them with submitting the claim on the plan member’s behalf. Keep in mind that officials recommend that patients maintain at least a 14- to 30-day supply of medication on hand but also warn against “stockpiling” as this creates an unnecessary risk of medication shortages.
To learn more about drug shortages in Canada: click here.
Virtual Services Available
- Virtual healthcare clinic available 24/7
- Available to everybody, but GSC provides these discounted rates:
- $43 per visit - weekdays from 7 a.m. to midnight ET, Monday-Friday;
- $69.50 per visit - weekends and holidays from 7 a.m. to midnight ET;
- $87 per visit - midnight to 6:59 a.m. ET
- Employees can submit this expense through HCSA
- For BC members- there is an option to use Maple that goes through MSP, thus no charge to the member. When they book the appointment online they can see the free option there (video visits only)
- Mail-order pharmacy with free next day delivery to your home
- Available to everyone, but BBD receives a discount on dispensing fee
- Refill medication by texting their toll-free number or calling them
Green Shield’s Mindfulness Program
- Six introductory sessions on mindfulness through GSC at plan member’s own pace
- Available to all GSC members
- No out of pocket cost for GSC members
- Receive personalized exercise video based on a couple of questions
- Available to all GSC members
- No out of pocket cost for GSC members
Employee and Family Assistance Plans (EFAP) and Mental Health Support
Employee Assistance Plan (for plans that include EAP)
If your client’s plan includes an Employee Assistance Program (EAP), we encourage you to remind them that this program is available to provide support to employees and their families during these challenging times.
For clients with HumanaCare’s EAP, HumanaCare’s best-in-class services are available through a host of mediums, including e-counselling and telephone counselling, to encourage social distancing. Contacting HumanaCare is easy - simply call 1-800-661-8193 24 hours a day, anywhere in North America, or email info@humanacare.com
Business Assistance Plan
If your client’s plan has Life Insurance through Benefits by Design (BBD) Inc. & Empire Life, they have access to a Business Assistance Program (BAP). A BAP helps employers access accredited legal, financial, and human resource professionals to navigate the complex problems arising within their business. Contacting HumanaCare is easy - simply call 1-800-661-8193 24 hours a day, anywhere in North America, or email info@humanacare.com
Member Communications Plan
We do not contact plan members directly however the carriers may be reaching out to plan members directly with general updates.