We know you’re tired of hearing about the pandemic, but this is pretty big. The Biden administration recently announced that the COVID-19 public health emergency and national emergency will officially end May 11, 2023.
Because this will affect your company’s group health benefits plan, here’s what experts are recommending:
- Ensure you have records that demonstrate compliance with COVID-era provisions in case you’re audited by federal or state authorities.
- Review your plan documents, procedures, policies, COBRA notices and other employee communications to ensure they’ll align with pre-pandemic rules in May.
- Review all health plan terms related to COVID-19, including testing, vaccines and treatment for the virus, then huddle with your plan provider to discuss all forthcoming plan amendments in benefit terms and offerings as a result of the non-renewal of the emergencies.
- Find out if this affects your plan sponsor costs and make any necessary adjustments.
- If you were offering employee assistance program (EAP) benefits to non-plan participants because EAPs were made temporarily exempt from many ERISA and ACA rules, will you discontinue it or make adjustments for ERISA and ACA compliance?
- Communicate changes to benefits terms and offerings to your employees. Be sure to highlight that COVID-related extended deadlines for claims, appeals and enrollment periods with insurers and third-party administrators may be winding down. This includes HIPAA special enrollment requests to enroll in a group health plan mid-year and COBRA elections.
Employees will also need to understand that with the expiration of the COVID-19 emergencies comes possible new or additional health costs for them. For instance, after May 11, they could be paying out-of-pocket for at-home test kits, COVID-related treatments, tests ordered or administered by a health professional and/or vaccines administered by an out-of-network provider.
COVID-19 telehealth relief extended
To soften the blow, there’s some good news if you have an HSA-qualifying high-deductible health plan. Pre-deductible telehealth coverage under these plans is not tied to the COVID-19 public health emergency or national emergency declarations. Because of that, the 2023 Consolidated Appropriations Act passed at the end of last year, which included the Secure 2.0 Act, has extended relief for telehealth and other remote care services through December 31, 2024.
Employers also have the option to grant a stand-alone telehealth benefit to employees who don’t qualify for other health coverage.