Accident & Health COVID-19 FAQ

Testing

Will Swiss Re Corporate Solutions accept policyholder coverage of COVID-19 testing at 100% coverage with no plan deductibles, coinsurance and/or co-payments?  If so, will there be any change required to current in-force premium rates or aggregate factors?

Yes, we will accept policyholder coverage of COVID-19 testing, including serological tests for antibodies, at 100% with no cost-sharing.  No amendment is necessary.  There will be no change to premium rates or aggregate factors for current in-force policies.

Treatment

Will Swiss Re Corporate Solutions accept policyholder coverage of COVID-19 treatment, including hospitalization, beyond testing or telemedicine, at 100% coverage with no plan deductibles, coinsurance and/or copayments? If so, will there be any change required to current in-force premium rates or aggregate factors?

Yes, we will accept policyholder coverage of COVID-19 treatment at 100% with no cost-sharing. Plan amendment is required. The amendment can be retroactive to March 1, 2020 if received by August 30, 2020. There will be no change to premium rates or aggregate factors for current in-force policies. 

Telemedicine

Will Swiss Re Corporate Solutions accept policyholder coverage of Telemedicine and video presence with no plan deductibles, coinsurance or and/or copayment for any diagnostic and necessary medical treatment? If so, will there be any change required to current in-force premium rates or aggregate factors?

Yes, we will accept policyholder coverage of Telemedicine and video presence at 100% with no cost-sharing. Plan amendment is required. The amendment can be retroactive to March 1, 2020 if received by August 30, 2020. There will be no change to premium rates or aggregate factors for current in-force policies.

Prescription refills

Will Swiss Re Corporate Solutions accept the removal of prescription refill limitations on maintenance medications to assure an adequate supply in the event of potential quarantine situation?

Yes, we will accept the removal of prescription refill limitations on maintenance medications. Plan amendment is required. The amendment can be retroactive to March 1, 2020 if received by August 30, 2020. There will be no change to premium rates or aggregate factors for current in-force policies.

Experimental and Investigative ("E&I")

Will Swiss Re Corporate Solutions reimburse treatments and services that might be effective for treating COVID-19 but fall under the Plan’s E&I exclusion (e.g., convalescent plasma, Tocilzumab and Remdesivir)?

We rely on the policyholder and their administrator to determine claims eligibility under the Plan. We will follow the Plan's provisions, and any amendment submitted and accepted by us for coverage under the stop loss policy, relative to E&I.

Closure and furloughs / Actively-at-Work

Can policyholders that close their businesses, or furlough employees, due to COVID-19 continue to consider plan members actively-at-work?

Yes. Plan members considered actively-at-work, or otherwise covered pursuant to the terms of the plan, the day before the closure may be considered actively-at-work no earlier than March 1, 2020. For the purposes of this provision, "closure" includes temporary furloughs or reduction in hours of some or all members.

Premium must be paid for all plan members considered by the policyholder to be covered and actively-at-work during the billing month.

Policyholders are required to provide notification of closure or furloughs. We will accept the following:

a) Permanent change to the plan allowing furloughed employees to remain eligible under the plan for up to 6 months. Plan amendment is required. We will accept an amendment that can be retroactive to March 1, 2020 if received by August 30, 2020.

b) Temporarily allowing furloughed EEs to stay on the plan until the earlier of: a) the end of the policy year, or b) December 31, 2020. No amendment is required but the policyholder must notify us within 60 days of the notice or furlough.

The policyholder must give notice in letter or email form and include the onset date of the closure or furlough. Notice from the policyholder must be received within 60 days of the closure or furlough.  Names of furloughed employees are not required. Stop loss claim reimbursement requests will require documentation of coverage eligibility.

Reduction in Number of Covered Individuals

How will a reduction in covered individuals of more than 15% from that shown in the application be handled?

If the policyholder elects to not extend coverage as noted above in "Closure and Furloughs / Actively-at-Work", standard policy provisions apply.

Premium Payment

Will Swiss Re Corporate Solutions extend policy premium payment provisions due to payment delays resulting from COVID-19?

Yes. Premium payment, including premium for COBRA continuees, may be made within 60 days of the due date until further notice. No notification is required.

Claims Filing Timelines

Will Swiss Re Corporate Solutions extend timely filing requirements for claims which are delayed as a result of COVID-19, including administrators' inability to process claims timely, PPO networks repricing claims timely and/or medical providers inability to bill timely?

We have not changed our Claims processes, procedures, requirements or policy provisions.

However, as indicated below, we will accommodate groups subject to extensions contained in the DOL/IRS Joint Rule. To the extent a plan conforms to the Rule, we will follow accordingly, subject to the terms of the Stop Loss policy.  

No Plan amendment is required. Stop loss claim reimbursement requests will require documentation of eligibility for coverage.

Claims Reimbursement

Will Swiss Re Corporate Solutions extend policyholder reimbursement deadlines?

No. We have not changed our Claims reimbursement processes, procedures, requirements or policy provisions.

Workers' Compensation

What is Swiss Re Corporate Solutions' position with respect to state rules and administrative orders automatically granting workers' compensation eligibility for individuals deemed essential workers?

We expect policyholders and administrators will follow the Plan provisions, and any applicable temporary state or federal statutes and rules, when adjudicating workers' compensation claims related to COVID-19. As most Plans have a workers' compensation exclusion, administrators should investigate those claims where there is a direct link between the member's occupation and contracting the virus, and take appropriate action regarding potential work-related claims. While we appreciate the related challenges, we expect that such claims would be filed as appropriate with the employer's workers' compensation carrier.

Utilization Review

Will Swiss Re Corporate Solutions accept suspension of utilization management review and notification ("UR") requirements?

Yes, as follows.

a) If required or requested by State or Federal rule:  
A number of states have requested that insurance companies suspend certain UR requirements in order to free up medical personnel to assist with caring for patients. In any such state, we will accept payment of claims without penalty for failure to comply with UR requirements. This will apply for the timeframe determined necessary by the plan, not to exceed the period of time requested by a given state.   

b) If NOT required by State or Federal Rule:
For groups not sitused in a state requesting suspension of UR requirements, we will accept such suspension for a period of up to 6 months. Plan amendment is required. The amendment can be retroactive to March 1, 2020 if received by August 30, 2020.

Policy Changes

Will Swiss Re Corporate Solutions allow policy changes or enhancements off anniversary such as Monthly Aggregate Accommodation or addition of Terminal Liability Option?

We currently do not allow these policy changes or enhancements off anniversary.

Federal Rules Extending COBRA, HIPAA and Claims Appeal Timelines

Will Swiss Re Corporate Solutions follow federal rules extending certain deadlines regarding COBRA, HIPAA and claims appeals?

Yes, we will accommodate groups that are subject to federal rules related to COVID-19, including the DOL/IRS joint rule ("Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak"), that extends deadlines with respect to certain COBRA requirements, HIPAA special enrollment periods, and claims appeals.

To the extent a plan conforms to the Rule, we will follow accordingly. No Plan amendment is required. Stop loss claim reimbursement requests will require documentation of eligibility for coverage.

Please note – the terms of the Stop Loss policy do apply. Therefore, we recommend that policyholders:

a) Carefully review policy terms for upcoming renewals, especially with respect to gaps that may occur relative to incurred and paid dates due to the extended timelines; and

b) Consider purchasing an appropriate policy basis to ensure claims will be incurred and paid within the policy period.

Special Enrollment Period / Mid-year Election Changes

Will Swiss Re Corporate Solutions accept plan members that join the plan, or change or revoke plan coverage, through mid-year election changes pursuant to IRS Notice 2020-29?

Yes, if policyholders elect to permit mid-year election changes during calendar year 2020, we will accept the following such changes on a prospective basis pursuant to all other terms of the plan:

a) new election of coverage, if the employee initially declined to elect coverage under the Plan;

b) change of an existing election and enrolling in different health coverage sponsored by the policyholder; and

c) revocation of an existing election.  

No Plan amendment is required.  Stop loss claim reimbursement requests will require documentation of eligibility for coverage.

Please contact your regional Business Development Manager if you have any questions.

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