Capital continues to look at all the questions coming to us from the market and will be releasing responses to producers and groups. Due to the unique situation we are all in, our normal guidelines are being relaxed so that employers have some flexibility regarding their health benefits.

Here is some initial guidance on your questions.

Q  Can employer groups keep laid off employees on their group coverage?

A:  For all commercial group market segments, if staff is still considered an employee but is on temporary leave/furlough/layoff and the employer has a written COVID-19 business continuity plan that will be applied uniformly to all staff in the same class of employees, they may remain enrolled in group coverage assuming the group continues to pay invoices.  If staff is permanently terminated, COBRA rules apply.

Q  If an employer group’s enrollment drops due to COVID-19, will the group be re-pooled or re-rated?

A:  No, not for their health care benefits. It should be noted that this is a temporary suspension of the process and normal guidelines will be reinstated when it makes sense to do so.

Q:  Is there a time limit for how long a laid off employee can remain on the plan?

A:  At this time we have no strict time limit but the group should document their policy as a special COVID 19 business continuity plan to help ensure no discrimination.

Q:  What happens if an employer extends coverage during the layoff?  Will Capital allow them to come back on the plan without having to meet the eligibility-waiting period?  If so, how long could one be laid off and not have to meet the waiting period?

A:  It is the group’s discretion to waive the waiting period upon return to work.  As long as they apply their policy uniformly, CBC has no issue with this. At this time we have no strict time limit but the group should document their policy as a special COVID 19 business continuity plan to help ensure no discrimination.