Tag Archives: coronavirus

How may social distancing affect Medicare Advantage organizations?

The COVID-19 pandemic has brought unprecedented stress and challenges to the healthcare industry. Based on the nature of the Medicare Advantage program and the predominantly elderly population it serves, Medicare Advantage organizations (MAOs) in particular face unique challenges. Beginning in early 2020, parts of the country implemented social distancing, with periods of closures or reduced capacity for many healthcare professional offices and postponement of nonurgent procedures at hospitals. Due to greater susceptibility, seniors may continue social distancing for more time and may be more hesitant to continue with normal social interactions, including receiving routine healthcare services.

In this article, Milliman’s David Koenig, Rob Pipich, and Michael Polakowski explain why MAOs need to be aware of the possible implications of these realities on their business and why they should address any issues now.

COVID-19 benefit changes: Action required for employer health insurance plans

This article reflects guidance issued through July 31, 2020; additional changes are possible in the future as the national emergency continues to unfold.

Recently enacted COVID-19 legislation and related federal guidance require some mandatory group health plan benefit changes and offer other voluntary changes you can elect to provide temporary relief to employees. Be aware that some of the changes require that you notify participants via a summary of material modification (SMM) or an updated summary plan description (SPD).

Now you have some work to do: Deciding which relief options to offer and notifying participants about the changes with an SMM or updated SPD. Communication is crucial, especially during this current crisis. With so many uncertainties these days, notifying participants about relief offered through their benefit plans can bring comfort and appreciation for their benefits.

Mandatory group health plan benefit changes

COVID-19 testing coverage

All group health plans (including high-deductible health plans) must cover COVID-19 testing and the doctor’s visit at 100% of the cost (with no cost sharing required of the employee). The plan must pay 100% of the incurred cost of a visit during which a COVID-19 test is administered or ordered, regardless of whether the provider is in- or out-of-network. This includes the cost of items and services related to the administration of a COVID-19 test in a variety of settings: office visits, urgent care, emergency room, drive-through, and telehealth.

When it comes to treatment of COVID-19, however, a recent publication by the U.S. Department of Labor affirms that employers have no mandatory responsibility to waive cost sharing for treatment of COVID-19 symptoms, and the plan’s normal deductibles, copays, and coinsurance may apply.

Suspension of deadlines during the “outbreak period”

The outbreak period for the COVID-19 crisis has been defined as beginning March 1, 2020, and ending 60 days after the national emergency period ends. As of mid-August (the publication of this article), the national emergency period has not ended. Certain group health plan compliance deadlines that would fall during this time have been paused until the national emergency ends. These changes apply to ERISA plans (both health and retirement plans).

What deadlines are affected?

  • HIPAA special enrollment, such as the 30-day election period following marriage, birth, or adoption of a child or loss of other coverage. As an example, if a participant was married on February 14, typically that person would have until March 15 to enroll a new spouse. That deadline is suspended during the outbreak period, and the participant will have until 15 days (time remaining in the original special enrollment period) after the end of the outbreak period to make changes. If, for example, the outbreak period ended on October 1, the participant would have until October 15 to enroll the new spouse.
  • Most participant COBRA deadlines, such as the 60-day period to elect COBRA and all COBRA payment deadlines. This delay gives qualified individuals and beneficiaries significantly more time to evaluate whether COBRA coverage is desirable or affordable, because they can wait until the end of the outbreak period and elect to pay for coverage retroactively.
  • Health flexible spending account (FSA) claim filing deadline. If the original deadline was March 31, 2020, for example, the new deadline will be 31 days after the end of the outbreak period. (Because they are non-ERISA plans, dependent care FSAs are not subject to this rule.)
  • ERISA claims and appeals deadlines for benefit claims, appeals of adverse decisions, and requests for external reviews of decisions are also delayed; claims are not required to be filed until the end of the outbreak period.

Keep in mind: Participants don’t have to wait until the end of the outbreak period to enroll or submit claims.

Voluntary group health plan benefit changes

In addition to these mandatory updates, recent federal guidance allows other voluntary changes to group health plans. If you choose to implement any voluntary provisions, they should also be included in your communication to participants.

For group health plans, you might be considering:

  • Relaxing deadlines for cafeteria plan elections
  • Allowing employees to make certain midyear changes to health plan and FSA elections
  • Extending the 2019 FSA grace period for incurring claims to December 31, 2020
  • Increasing the health FSA carryover from $500 to $550

Show support for your employees

Employees need to hear from you during these challenging times—especially with some good news. Take a close look at what you can do with your benefits program to ease the pressure on employees and support them in some very practical ways.

Why are U.S. nursing homes at high risk for COVID-19 contraction?

Emerging data from around the world suggest that nursing home residents are at exceptionally high risk for contracting COVID-19, with some areas reporting that close to half of regional deaths are either in nursing homes or in hospitals after admission from a nursing home. Less than 0.5% of Americans live in nursing homes, but the remarkable concentration of risk in such facilities may have profound implications on how we handle the pandemic.

In this article, Milliman’s Bruce Pyenson and Harvard’s David Grabowksi discuss why nursing homes have been hit so hard by COVID-19 and what can be done to fight the disease in these facilities.

COVID-19 and proposed ACA market premium impact

Expected costs related to COVID-19 may increase or decrease health insurance premiums in the Patient Protection and Affordable Care Act (ACA) commercial markets. When setting premiums for 2021, health insurers will consider a variety of factors related to virus, including the acute treatment and vaccination for COVID-19, changes in access and demand for healthcare, lasting effects on population health, economic effects on enrollment and utilization of care, and other operational effects.

The National Association of Insurance Commissioners (NAIC) has released a template to assist state regulators in their reviews of 2021 premium impact assumptions for COVID-19. The template outlines a number of pricing considerations.

As of June 15, 2020, six states and the District of Columbia have publicly released preliminary ACA premium rates for 2021. This paper by Milliman’s Dane Hansen, Andrew Bochner, and Emily DeAngelis examines the reported impact of COVID-19 on these rates.

Communicating to employees during a pandemic

This spring has been an interesting and challenging time to be a business leader. As the workplace location, habits, and culture across the board have been turned inside out, leaders have had to think differently.

Returning to the workplace

While the move to working from home happened quickly, the return to work will be slower and more complicated. If you haven’t made movement back to workspaces and office buildings, think carefully about all of the implications of our new six-feet-apart world. How will you handle an employee who refuses to wear a mask when required? When will you open the kitchens and make coffee and water available? How many people will you allow in a restroom at a time? Do people have to walk clockwise around the space? Where do you put hand sanitizer stations? Setting aside all of the logistics, how do and will employees feel?

Tips for employee return-to-workplace communication

Like any other workplace change, making sure employees are aware and understand this new world will be equally as important as the actual changes themselves. Training, education, and effective communication are key aspects of many of the local requirements for returning to office buildings. Required or not in your area, they should be your top priority in the process of returning employees to any common workplace, in any location. As you begin to think through your employee communication strategy, below are a number of tips to keep in mind as you communicate return-to-workplace situations. We recommend working in partnership with a trained consultant and your legal counsel to ensure that you meet the requirements for your location (if any) and so that your employees recognize you take their health and safety seriously and understand what is expected of them.

  • Start with developing a clear and detailed safe work plan; review any policies that need to be updated
  • Write in plain, easy-to-understand language
  • Use images and diagrams where appropriate
  • Outline what the building management is doing, how the company is supporting this effort, and clear expectations for employees
  • Partner with Human Resources and legal counsel; they can help you steer clear of perceptions of discrimination and other potential employee relations or legal issues
  • Get input from your senior leaders; they should be knowledgeable and included well before you communicate to employees
  • Train your managers and supervisors on the safe workplan and what is expected of them; they are the front line of employee communications
  • Use different media to supplement a written plan; hold a webinar and record it; create a video; leverage your online employee portal; do a podcast
  • Make good use of signs throughout the office to help with key behaviors
  • Be clear where employees should go with questions
  • Start communicating well before individuals are allowed (or expected) to return to the workplace
  • Explain that the situation is fluid and manage expectations by noting that when new information becomes available the plan will be updated; communicate those key changes with leadership and employees

Careful not to overdo it

Especially now, employees want to understand what you are doing to keep them safe and to believe that you care. But you don’t want to overdo it either. Whether it’s due to a lack of trust or excess worry, some organizations are holding many more meetings than usual to “check-in,” which employees can find invasive and intrusive. If “eyes on your employees” was your primary form of performance evaluation, you might be feeling unsettled in this new work-from-home arrangement. In most situations, you’ve likely hired responsible, talented people who want to, and will, do good jobs under any circumstance. Trust they will and reward them when they do. Tip: Let them dictate the check-in frequency. Be willing to tailor your approach to the communication needs of the individual(s) or group(s). Then, over time, survey your employees and ask them how it’s working (the frequency, content, etc. of the communications).

Wherever you are along this journey, just don’t forget employees’ needs have shifted and will likely continue to change. Be flexible and willing to adjust your communication approach constantly. As you prepare for the next phase, whatever that might be for you, look for that Goldilocks communication approach—not too much, not too little, but just right.

Understanding the path to COVID-19 vaccination

Vaccinations have historically been shown to boost a person’s immune system, eliminate and prevent the spread of infections, and lessen the burden on the healthcare delivery system. The concept of using vaccines has been around since the 1500s with several accounts describing smallpox inoculation as practiced in India and China.

Vaccines undergo strict testing and research under U.S. Food and Drug Administration (FDA) standards prior to becoming available to the public. Vaccinating populations has helped countries take steps toward wiping out debilitating and deadly infections such as polio and smallpox.

In view of the COVID-19 pandemic, Milliman’s Stephen George has written a new paper focusing on:

  • Examining why, when, and how vaccines are used
  • Highlighting the vaccine development pathway
  • Reviewing previous experience with viral pandemics
  • Assessing ways payers can address COVID-19