BENEFIT CHANGES RESULTING FROM THE END OF THE COVID-19 PUBLIC HEALTH EMERGENCY
In January 2020, the Secretary of Health and Human Services established the Public Health Emergency for COVID-19 (“Public Health Emergency”). Pursuant to related legislation, the Plan was required to make certain changes to your benefits for the duration of the Public Health Emergency, and you received various notices from the Plan describing those changes. The federal government has announced the Public Health Emergency will end at the end of the day on May 11, 2023.
Below is a description of how the end of the Public Health Emergency will impact your Plan benefits.
1. COVID-19 Vaccines Through December 31, 2023 — The Plan will continue to cover approved COVID-19 vaccines and vaccine boosters at 100% with no deductible and no cost-sharing, whether received from a Preferred Provider, Nonpreferred (Participating Provider), or a Nonpreferred (Nonparticipating Provider). Effective January 1, 2024 — The Plan will cover approved COVID-19 vaccines and vaccine boosters the same as any other preventive care benefit as follows:
Preferred Providers: 100%, no deductible
Nonpreferred (Participating Providers):100% of Allowed Amount,* no deductible
Nonpreferred (Nonparticipating Providers): 100% of Allowed Amount,* no deductible
*You may be responsible for the difference between what the Plan pays (the “Allowed Amount”) and what the Provider bills the Plan.
2. COVID-19 Diagnostic Testing (Excluding Over-the-Counter Tests) Through December 31, 2023 — The Plan will continue to cover diagnostic COVID-19 tests at 100% with no deductible and no cost-sharing, whether received from a Preferred Provider, Nonpreferred (Participating Provider), or a Nonpreferred (Nonparticipating Provider). Effective January 1, 2024 — The Plan will provide coverage for diagnostic COVID-19 tests the same as any other laboratory test as follows:
Preferred Providers: 80%, deductible applies
Nonpreferred (Participating Providers): 60% of Allowed Amount, deductible applies
Nonpreferred (Nonparticipating Providers): 60% of Allowed Amount,* deductible applies
*You may be responsible for the difference between what the Plan pays (the “Allowed Amount”) and what the Provider bills.
3. Over-the-Counter (“OTC”) COVID-19 Tests Through December 31, 2023 — The Plan will continue to reimburse up to eight OTC COVID-19 tests per month per eligible family member for tests obtained through ExpressScripts. Reimbursement is limited to $12 per test. Effective January 1, 2024 — The Plan will no longer provide reimbursement for OTC COVID-19 tests.
4. Virtual Care Telehealth The Plan’s Virtual Care Telehealth benefit will continue to be available with no changes. END OF CERTAIN PLAN DEADLINE EXTENSIONS Separate from the Public Health Emergency, the COVID-19 National Emergency became effective on March 1, 2020. Related guidance required the Plan to disregard the period beginning March 1, 2020, and ending 60 days after the end of the National Emergency (the “Outbreak Period”) when calculating the deadlines listed below. The Plan will no longer be required to disregard the Outbreak Period as of July 10, 2023. This means the timeframes listed below will begin (or resume) running as of July 11, 2023.
- HIPAA Special Enrollment Period – The 31-day period to enroll dependents following the birth, adoption/placement for adoption, marriage, or loss of other coverage (60-day period for a participant to enroll dependents following the loss of eligibility under CHIP or Medicaid).
- COBRA:
– 60-day election period. COBRA premium payment due date (45 days after the initial COBRA election and 30 days for subsequent monthly payments).
–30-day period to notify the Plan of a divorce, legal separation, death, or disability determination by the Social Security Administration. - Claims and Appeals – Deadlines for filing a claim, an appeal of a denied claim, or a request for external review of a denied appeal. The examples below illustrate how the end of the Outbreak Period impacts Plan deadlines:
Example 1. John’s 60-day period to elect COBRA began on December 31, 2022 (i.e., during the Outbreak Period) and would normally end on March 1, 2023. During the Outbreak Period this 60-day timeframe to elect COBRA was tolled until the end of the Outbreak Period (July 10, 2023). John has until September 8, 2023 (60 days after the end of the Outbreak Period) to elect COBRA.
Example 2. Mary gave birth to a child on November 15, 2022 (i.e., during the Outbreak Period). Mary would normally have had until December 16, 2022, to enroll her child in the Plan (i.e., 31 days from the birth of her child). The deadline for Mary to enroll her child was tolled until the end of the Outbreak Period (July 10, 2023). Mary has until August 10, 2023 (31 days after the end of the Outbreak Period) to enroll her child in the Plan.
Example 3. Victor receives a claim denial letter on August 1, 2023 (i.e., after the end of the Outbreak Period). Because the Outbreak Period has ended, there is no tolling and normal deadlines apply. Victor must file an appeal within 180 days of the date he received the claim denial letter.
If you have any questions regarding this notice, please contact the Administrative Office at (866)239-1708.
In accordance with the requirements of the Employee Retirement Income Security Act of 1974, as amended (ERISA), this notice serves as a “summary of material modifications” to the Plan. Please keep this summary with your copy of the Plan booklet. In the event of any conflict between this document and any other written or oral statement regarding these Plan changes, this document will control.