Cost Sharing Waivers

Most health insurance carriers have announced an extension to the policy of waiving copayments, coinsurance and deductibles for COVID-19 medically necessary diagnostic testing through September 30, 2020. Guidance on what services are considered medically necessary is provided by the FFCRA and the CARES Act as well as the California Department of Managed Care.

In addition, many carriers are waiving copayments and coinsurance for Teledoc services, whether or not they are related to COVID-19, through the end of September.

There may be variations on these benefits by carrier, and your Johnson & Dugan team can assist you with determining the impact to your plan.


COBRA Premium Payment Extension

The Department of Labor, Internal Revenue Service and Treasury Department released a notice that extended certain health plan deadlines to offer flexibility for plan participants during the pandemic. COBRA premium payment deadlines are included in this extension, which will require plan sponsors to modify their procedures for handling late premium payments during the Outbreak Period*.

The attached COBRA Premium Grace Period letter can be used by companies handling COBRA administration who need to communicate this flexibility to their COBRA participants. The letter details the standard premium due date and the extended due date. It also includes an explanation of the extension and how coverage is impacted when taking advantage of the premium payment delay.

Plan Sponsors should review the status of all COBRA participants to ensure they have been offered the available deadline extensions. It is important to keep in mind that these extensions don’t start the clock over for COBRA deadlines. The remaining time in the payment period starts up once the Outbreak Period is over.

See the Department of Labor COVID-19 FAQ page for more information:

The United Benefit Advisors (UBA) Advisor Final Rule on the Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Due to COVID-19 also provides additional details about this rule.

* The Outbreak Period is the period of time ending 60 days after the date the pandemic emergency is declared over.


Bringing Employees Back to the Office

The California Department of Public Health has published COVID-19 Industry Guidance: Office Workspaces: