Given the rising Covid-19 cases, let’s review some basic, yet confusing, healthcare acts that may impact your group health plan.
Update This Past Fall
Effective October 13, 2022, the COVID-19 public health emergency was again extended through January 11, 2023, by the Department of Health and Human Services (HHS), as anticipated. This extension impacts group health plan coverage requirements related to COVID-19 testing and related services. Pending the health of our population and politics, maybe the COVID-19 public health emergency will be extended again. Please see more below.
The Families First Coronavirus Response Act (FFCRA) generally required group health plans, including fully insured and self-insured plans, and health insurance issuers to provide benefits for items and services related to the testing and diagnosis of COVID-19 as of March 18, 2020, and through the end of the public health emergency period declared by HHS, which is now extended.
This coverage must be provided without cost-sharing requirements (including deductibles, copayments, and coinsurance), prior authorization, and the insurer to control expenditures and utilization of comparable drug brands.
In addition, the Coronavirus Aid, Relief, and Economic Security (CARES) Act amended the FFCRA to include a broader range of items and services that must be covered, including coverage for approved COVID-19 vaccines. Per the CARES Act, coverage for the COVID-19 vaccine must be provided by non-grandfathered group health plans without cost sharing, regardless of whether an in- or out-of-network provider administers the vaccine. However, once the public health emergency ends, the COVID-19 preventive-services coverage mandate will continue to apply, but only on an “in-network” basis.
Group Health Plan Impact
With the public health emergency still effective, group health plans must continue to provide coverage related to the testing (including specific over-the-counter tests) and diagnosis of COVID-19 without cost-sharing requirements, as described above. Similarly, coverage for the COVID-19 vaccine must be provided, by non-grandfathered group health plans, without cost sharing for in- and out-of-network providers.
While there is no immediate action at this time, employers should be aware of these developments. PT Business Solutions will continue to monitor and communicate updates.