Florida Blue Group Health plan flexibility due to COVID-19

We recognize that some companies may be adjusting to better support their employees during this unusual time. We also know there are a lot of questions surrounding the benefits that are offered to teams and what effects the COVID-19 pandemic could have on those. We hope this helps you understand and navigate through some of the top concerns we’re seeing.

1. Will Florida Blue be extending grace periods beyond 30 days for premium payments?

• Yes. Florida Blue has committed to payment flexibility and no cancellations for nonpayment of premium through May 31, 2020. There will still be past due amounts on invoices that will be due at the end of this period but no coverage will be terminated.

2. Some insurance companies are offering a one-time special enrollment opportunity which will allow employees to come onto the plan or add dependents. Will Florida Blue be offering a special enrollment opportunity to mirror a qualifying event? If yes, does this also allow an employee to drop their plan during this special enrollment period too? Will this allow them to change between plans?

• Yes. For groups that renewed on March 1, we are extending the open enrollment period to April 15. All other groups have 30 days beyond the effective date to enroll their employees. (example: March 15 effective date will have until April 15 to complete open enrollment, April 1 effective date has until April 30, etc) Also, Florida Blue is implementing a special enrollment period from April 1–April 15, 2020 for employees that previously refused coverage or are adding dependents to a contract. Only groups enrolled with Florida Blue prior to March 1, 2020 are eligible for this special enrollment period. It is limited to employees who did not elect coverage or waived coverage prior to March 1, 2020. Dependents (such as spouses and children) can be added if enrolled in the same coverage or benefit option as the employee.

3. If a company is reducing hours and/or laying off staff due to the COVID-19 crisis, are they able to keep their employees covered on the plan?

• Florida Blue has adopted a non-enforcement policy that will apply to currently enrolled eligible employees that will allow them to retain coverage as if they were active employees, even if they are furloughed or drop below the normal minimum hours required to be worked for full time employees (25 hours/week for small employers and generally 30 hours/week for large employers). This non-enforcement policy will apply until April 15, at which time it will be reevaluated. If terminated altogether, the former employee can either elect to continue coverage through COBRA or will qualify for a Special Enrollment Period to purchase an individual plan. If the terminated employee is rehired at a later date, there is no standard waiting period to re-enroll in group coverage but they will still need to meet the normal eligibility requirements.

4. If a company is being forced to shut down by state or government orders, can they keep their Small Group Insurance?

• In order for a group to remain active during this period up to May 31, 2020, the group must retain at least one active employee. Failure to retain at least one active employee will result in the group’s cancellation. The group may make the decision to furlough or lay off employees during this time as well. Ultimately, the group will owe premiums through May 31 for any active employee that remains on the active roster for coverage.

Prevent your next HR nightmare!

Think you don’t need an Employee Handbook or that yours is sufficient as is? Think again. It is extremely important to keep a current Employee Handbook.

Some misconceptions of business owners or HR directors may be:
• No time or resources
• It’s too much work
• Afraid we’ll miss important compliance/law changes
• Not a company priority
• Don’t think a Handbook is necessary for our business
• We’ve already finished our updates this year

Your Handbook does a lot for you that shouldn’t be overlooked, such as:
• It tells your story and you have the opportunity to be a really great narrator
• It sets the tone for your company culture and clearly communicates the mutual expectations with your employees
• It explains your purpose, your why and your how
• It defines and explains the benefits you offer to your staff, adding value and morale to your operation
• Your openness and transparency will go a lot further than you might expect
• Delivers brand or information change promptly and efficiently

There could be substantial consequences of not having an accurate, up-to-date Handbook:
• Your exposure to legal action being taken against you
• Missing or inaccurate information is misleading
• Employees may not feel comfortable going to management when they should be able to refer to the Handbook to avoid feeling hesitant
• Staff will not feel confident if there’s a lack of guidance and support from their leadership
• Changes in state/federal laws that affect your policies will be overlooked
• Harassment and discrimination issues could be avoided

As always, if there are ways we can help with your Employee Handbook or implementation of it, please contact us any time at (352)371-7977 or [email protected].

The IRS Holiday Gift to Large Employer Health Plans

The IRS has an early holiday gift for employers, on November 29, 2018, the IRS released an extension for large employers to file the 2018 Form 1095-C or 1095-B under the Affordable Care Act requirements. The agency has pushed back a critical Affordable Care Act (ACA) deadline for the fourth year in a row.  The forms, which outline employer-provided medical benefits, must be submitted annually by businesses with 50 or more full-time workers. The IRS uses these reports to track employer compliance.
-The deadline for furnishing 2018 Form 1095-C, or Form 1095-B, if applicable, to employees and individuals is March 4, 2019 (extended from January 31, 2019).

-The deadline for filing copies of the 2018 Forms 1095-C, along with transmittal Form 1094-C (or copies of Forms 1095-B with transmittal Form 1094-B), if applicable, remains unchanged:

-If filing by paper, February 28, 2019.

-If filing electronically, April 1, 2019.

The extended due date applies automatically so employers do not need to make individual requests for the extension.