Employee Benefits During COVID-19

On Wednesday ABC members participated in a webinar facilitated by IMA Corp experts on the popular topic of employee benefits resources during COVID-19. Construction employers are working diligently to provide information to their team members and connect them with applicable resources. ABC and IMA were happy to team up to help answer these important questions. 

You can find our post on wellbeing & mental health here.

High Deductible Health Plan Coverage

• IRS Notice 2020-15 
• High-deductible health plans (HDHPs) may provide benefits for COVID-19 testing and treatment with no deductible without compromising HSA eligibility 
• Does not require coverage (but FFCRA does require coverage of testing only) 
• CARES Act 
• HDHPs can cover telehealth or other remote care services at no deductible

Family First Covid19 Response Act: Mandated Testing Coverage

• Under the FFCRA, GHPs must cover approved testing for COVID-19 without cost-sharing or medical management
  • CARES Act has expanded this mandate to apply to additional approved forms of testing, such as state-approved tests
• Applies to all GHPs – including fully insured, self-insured, and grandfathered plans
• Effective from April 1 until the end of the public health emergency

Tax Credits for GHP Expenses

• FFCRA allows covered employers to take payroll tax credits to offset paid leave under that law 
• The tax credits can also be used for expenses related to providing or maintaining group health coverage
  • Generally means premiums or the equivalent under a self-insured plan
• Credit is available to the extent the GHP expenses are “allocable” to required leave payments

Continued Coverage Following Employment Changes

• Coverage typically requires meeting eligibility criteria (hours of service) 
• Layoffs, furloughs, reduced hours, or non-FMLA leaves of absence may cause loss of eligibility under the plan
  • Other approved leaves may require coverage continuation per employer policy
  • Otherwise, COBRA would typically be offered in these circumstances
• Many insurers (including stop-loss) are allowing employers to extend coverage beyond what the plan allows
  • Some allow this automatically, others require plan amendments
• Do NOT extend coverage without obtaining approval from carriers and stop-loss
  • Check with your benefits consulting team for coverage information specific to your plan

Mid-Year Benefit Changes

• Some insurers have announced special enrollment opportunities for employees to enroll due to COVID-19 
• Cafeteria plan rules would not normally treat this as a qualifying event 
  • BUT significant improvements in coverage (e.g. COVID-19 testing/treatment with no cost-sharing) might be sufficient to justify a QE 
  • IMA anticipates that the IRS will be lenient with employers in these circumstances 
• Probably okay to allow employees to move from a higher-cost plan to a lower-cost plan 
• Health, disability, and life insurance may be crucial during this crisis – help employees understand importance before dropping coverage 
  • Insurance voluntarily dropped will not get COBRA 
• Get carrier approval first! 

Resources

― General FAQs: https://imacorp.com/benefits/wp-content/uploads/sites/3/2020/03/EB-COVID-19-FAQs_031920.pdf

Thank you again to the team at IMA for leading this important discussion and providing this outline of resources available to the industry and community. 

Please email info@abcksmo.org with any questions you may have. And be sure to check out our other blogs & resources on COVID-19 here and watch for future webinars to register for on our events page here.