COVID-19: Broker and employer resource center

A comprehensive guide addressing general questions you may have about health risks, safety measures, and other best practices when returning to the worksite.

View on the CDC website

A decision tool with step-by-step questions to help you determine your readiness for reopening your workplace.

View on the CDC website | Download the decision guide (.pdf)

A portal for worker safety, support and communication resources to refer to in the reopening process.

View on the CDC website

A toolkit to help employers prevent the spread of COVID-19 and lower the workplace impact for non-health-care business settings.

View on the CDC website | Download the toolkit (.pdf)

Interim guidance for protecting workers at higher risk for severe illness from COVID-19, such as individuals over age 65 and those with underlying health conditions.

View on the CDC website

Recommendations for small businesses on protecting employees and preparing your business for disruption.

View on the CDC website | Download print-friendly version (.pdf)

Advice for creating safe and healthy office environments and protecting workers and clients.

View on the CDC website

Tips from the CDC to minimize the risk of mold and Legionnaires’ disease in your building’s water system.

View on the CDC website

CDC recommendations for developing a plan and determining what needs to be cleaned and disinfected.

View on the CDC website | Download print-friendly version (.pdf) | Download the decision tool (.pdf)

No, members will not have to pay cost sharing for the emergency use authorization (EUA) COVID-19 vaccines.

The COVID-19 vaccine is available at mass vaccination sites and select retail pharmacies. It may also be available through certain hospitals, medical practices and local boards of health. Visit www.vaccinefinder.org or check your state government’s website to find out where the COVID-19 vaccine is available in your area:

• Connecticut
• Maine
• Massachusetts
• New Hampshire

The federal government is paying for the vaccine itself, and insurers are covering the cost of vaccine administration.

Yes. On March 31, 2020, Harvard Pilgrim made the decision to waive member cost sharing (deductibles, copays and coinsurance) for COVID-19 treatment provided by in-network providers. Cost sharing for emergency services related to COVID-19 treatment administered by out-of-network providers will also be waived.

The updated policy applies to all Harvard Pilgrim fully insured commercial, Medicare Advantage and Medicare Supplement members.

Self-insured employers with plans administered by Harvard Pilgrim needed to notify Harvard Pilgrim by Tuesday, April 7, 2020, of their intention to opt out.

The enhanced policy is effective until further notice. Harvard Pilgrim will reassess as circumstances warrant. In addition, any claims previously received for COVID-19 treatment prior to this policy going into effect will be covered consistent with this policy.

Yes. The waiver of cost sharing for treatments of COVID-19 applies to high-deductible health plans administered by Harvard Pilgrim.

We want to help remove any potential barriers for our members seeking treatment related to COVID-19.

Members are covered without cost sharing for COVID-19 testing, including antibody testing, until further notice.

Consistent with federal and state guidance, COVID-19 tests will only be covered or reimbursed if they are medically necessary, as determined by a health care provider, in accordance with current CDC and state public health department guidelines. COVID-19 tests that are not ordered or referred by a provider are not covered benefits. Testing will not be covered solely for general workplace health and safety, public health surveillance, or other purposes not primarily intended for a member’s individual COVID-19 diagnosis or treatment, except for Maine members when in compliance with and required by the state of Maine regulatory guidelines.

We will update this information as new guidance is issued.

Members should always use participating providers/laboratories for all COVID-19 testing.

At-home COVID-19 PCR (polymerase chain reaction) tests are covered with orders or referrals from a physician or attending provider. Home tests that members order themselves, including through an online self-completed questionnaire, are not covered for reimbursement.

Under ARPA, “Assistance Eligible Individuals” (defined in a later FAQ), are eligible for COBRA premium assistance from April 1, 2021, through September 30, 2021.

It is the employer’s responsibility to determine eligibility and notify beneficiaries who may be eligible for ARPA premium assistance under COBRA or state continuation of coverage (mini-COBRA). The Department of Labor (DOL) has issued guidance on operation of COBRA premium subsidies and model notices.

It is also the employer’s responsibility to provide notice to Harvard Pilgrim Health Care, identifying those beneficiaries who are eligible for ARPA premium assistance and have elected COBRA or state continuation of coverage (mini-COBRA).

For premium payment and tax credit responsibilities, see below.

• If the group health plan is subject to federal COBRA (i.e., the employer maintaining the plan employed 20 or more employees in the prior year), coverage would be managed by the employer group. The employer would pay the premium for persons enrolled in COBRA between April 1, 2021, and September 30, 2021, and seek the associated tax credits.
• If the group health plan is not subject to federal COBRA, then mini-COBRA or comparable state continuation of coverage may apply, and the insurer will pay the premium between April 1, 2021, and September 30, 2021, and collect the associated tax credits. We are anticipating further guidance regarding operation of mini-COBRA or comparable state continuation of coverage that could impact this. We will update this FAQ accordingly.

Yes, retroactive coverage is allowed. However, an individual may not be eligible for the ARPA COBRA premium assistance, which follows the existing COBRA required deadlines to elect.

Due to the COVID-19 National Emergency, DOL, the Department of the Treasury and the IRS issued guidance extending timeframes for certain benefit-related deadlines (e.g., the COBRA election period) under private-sector employment-based group health plans. See EBSA Disaster Relief Notice 2021-01. Under the EBSA Disaster Relief Notice, individuals and plans with timeframes that are subject to the above-noted relief (i.e., COBRA election period) will have the applicable periods disregarded until the earlier of (a) one year from the date they were first eligible for relief, or (b) 60 days after the announced end of the National Emergency (the end of the Outbreak Period). On the applicable date, the timeframes for individuals and plans with periods that were previously disregarded under the EBSA Disaster Relief Notice will resume. In no case will a disregarded period exceed one year.

If a qualified beneficiary, for example, would have been required to make a COBRA election by March 1, 2020, the EBSA Disaster Relief Notice delays that requirement until February 28, 2021, which is the earlier of one year from March 1, 2020, or until the end of the Outbreak Period (which remains ongoing). Similarly, if a qualified beneficiary would have been required to make a COBRA election by March 1, 2021, the election requirement is delayed until the earlier of one year from that date (i.e., March 1, 2022) or the end of the Outbreak Period. Likewise, if a plan would have been required to furnish a notice or disclosure by March 1, 2020, the relief under the Notices would end with respect to that notice or disclosure on February 28, 2021. The employer is required to ensure that the notice or disclosure was furnished on or before March 1, 2021.

Under ARPA, to be eligible for the COBRA premium assistance a person must elect COBRA coverage within 60 days of the COBRA election notice. The COBRA extensions under the EBSA Disaster Relief Notice outlined above do not apply to the ARPA COBRA election periods. Therefore, employers and COBRA qualified beneficiaries must follow the timeframes specified in the ARPA for COBRA premium assistance to apply.

It’s our understanding that for federal COBRA (20+ employees), the employer would pay and collect the tax credit (for coverage between April 1, 2021, and September 30, 2021). If the former employee is looking to retroactively enroll in federal COBRA prior to April 1, 2021, under the DOL/IRS rules, then the employer may seek back premiums to retroactively restore coverage, but the individual is likely not eligible for ARPA COBRA premium assistance.

“Assistance Eligible Individuals” (AEIs) are eligible for COBRA premium assistance under ARPA. An AEI is someone who, during the period from April 1, 2021, through September 30, 2021, 1) is eligible for COBRA (COBRA qualifying event must be involuntary termination of employment [other than for gross misconduct] or involuntary reduction in hours), and 2) elects COBRA.*

It’s our understanding that four categories of individuals are impacted by ARPA and are considered AEIs. If the individual falls into one of the two categories outlined below, then the COBRA effective date would follow existing COBRA rules (i.e., coverage begins on the date of the qualifying event that caused the loss in coverage):

1. Individual elected COBRA prior to April 1, 2021, and remains on COBRA past April 1, 2021

2.  Individual becomes eligible and elects COBRA in a timely manner between April 1, 2021, and September 30, 2021

If an individual falls into the remaining two categories outlined below, they will receive an additional COBRA election opportunity and can begin their coverage prospectively from the date of their election, or, if they have a qualifying event on or before April 1, choose to start their coverage as of April 1, even if they receive an election notice and make such election at a later date. Coverage would end on the date COBRA would have been exhausted if elected in a timely manner or if it was never discontinued:

3. Individual was eligible to elect COBRA prior to April 1, 2021, but waived it or missed the election period, but if they had previously elected it, they would still be receiving COBRA continuation past April 1, 2021

4. Individual elected COBRA but discontinued it prior to April 1, 2021, but if they didn’t discontinue, they would still be receiving COBRA continuation past April 1, 2021

For all of the above categories except for #2: If the initial COBRA qualifying event was November 1, 2019, and the COBRA coverage had an 18-month maximum coverage period, COBRA would run until May 1, 2021 (past the April 1, 2021, COBRA premium assistance start date). The individual may be eligible for COBRA premium assistance for the month of April.

* ARPA does not extend the maximum COBRA coverage period. An individual is not eligible for COBRA premium assistance if they are eligible for other group health coverage, such as through a new employer’s plan or a spouse’s plan (not including excepted benefits, a qualified small employer health reimbursement arrangement [QSEHRA] or a health flexible spending arrangement [FSA]), or if the individual is eligible for Medicare.

Harvard Pilgrim is taking measures to allow for the extended deadlines affecting COBRA continuation coverage, special enrollment periods, claims for benefits, appeals of denied claims, and external review of certain claims.

According to the federal guidance, the national emergency due to the COVID-19 outbreak began on March 1, 2020. At that point, timelines associated with COBRA, making enrollment changes due to qualifying events, submitting and appealing claims, and external claims review were paused. Those timelines will resume 60 days after the federal government announces that the national emergency is over. The federal government has not yet announced the end of the national emergency.

Employers should consult with their attorneys to determine the appropriate timing requirements and COBRA compliance under their plans.

Updated January 29, 2021

Fully insured employers in Connecticut, Massachusetts and New Hampshire

Through July 1, 2021 or the end of the declared public health emergency, whichever happens first, Harvard Pilgrim will temporarily relax the number of hours (from 20 to 0) an eligible employee currently enrolled in the plan must work to remain eligible for group health coverage. This will also apply to employees who have been furloughed (i.e., they are still employed but have been placed on a temporary leave of absence by their employer solely as a result of COVID-19 closures).

To be eligible, the employer’s group policy must be active with all premiums paid on a timely basis, including those for individuals on leave; in addition, one bona fide employee has to be and remain covered under the employer’s group policy. Coverage under these relaxed requirements is limited to current employees who, immediately prior to the date of this new requirement, were working at the employer’s premises and can no longer work due to the COVID-19 pandemic.

Fully insured employers in Maine

The same policy above applies to Maine employers; however, in accordance with the March 12, 2020 Supplemental Order Regarding Continuation of Group Health Coverage issued by Gov. Janet T. Mills (24-A M.R.S. § 471), no date has been specified for this policy to be terminated.

Self-insured employers

Coverage for furloughed employees depends on the employer’s decision; it would need to be permitted by the terms of the plan or the plan would need to be amended to allow for coverage. Employers should also check with their stop loss carrier to confirm that the stop loss carrier will permit such coverage.

Note: This answer clarifies and replaces the answer from our 3/24/20 email.

Fully insured employers

Small groups (fewer than 20 employees): We will provide benefits to small employers in accordance with applicable “mini COBRA” under state continuation.

Large groups (more than 20 employees): We will provide benefits to large employers in accordance with federal COBRA law.

To be eligible, the employer’s policy must remain in effect and cover at least one employee for whom a COBRA qualifying event has not occurred. Harvard Pilgrim will not provide COBRA coverage unless there is at least one employee covered under the policy as a result of currently satisfying all applicable eligibility requirements, including, but not limited to, working the required number of hours.

Self-insured employers

Employees of self-insured businesses who lose their group coverage can elect COBRA in accordance with applicable law. COBRA eligibility decisions under self-insured plans are made by the employer as the plan administrator. Neither Harvard Pilgrim nor its affiliates are the plan administrator. Questions about COBRA under a self-insured plan should be addressed to the employer as the plan administrator.

Please note: Employees that lose group health coverage may in certain cases also obtain health coverage through the state Exchange program and may be eligible for premium assistance through the Exchanges.

Yes. Harvard Pilgrim will allow these employers a one-time special enrollment period during the employer’s current plan year and until the announced end of the national emergency.

• New plan elections will be limited only to less-rich plan designs or “buy downs” (e.g., the employer’s current plan with a higher deductible)
• Employers who want to offer a special enrollment period must notify Harvard Pilgrim 10 days in advance
• The special enrollment period must be only for 30 days

This is an employer decision. We advise employers to consult your broker, consultant and/or legal counsel on the risk of waiving waiting periods mid-year. Self-insured customers should also consult their stop-loss carriers to ensure that such waiver is permitted.

Yes, if an employer temporarily lays off a member and then rehires the member, a deductible consumption will be credited to the member’s “account” if the rehire occurs within the same plan year as the date of lay off.

On a case-by-case basis, Harvard Pilgrim will consider a one-time extension of the statutory grace period for the payment of premiums to 30 days. In addition, Harvard Pilgrim is in compliance with all state specific regulations and published guidance in each of our markets. Your Account Executive is available to address your questions.

This is an employer decision. We advise employers to consult your broker, consultant and/or legal counsel on the risk of relaxing its minimum participation requirements mid-year. Self-insured customers should also consult their stop-loss carriers to ensure that such waiver is permitted.

Harvard Pilgrim has launched a series of complimentary virtual offerings to support members’ well-being–from webinars filled with useful, relevant tips, to live mindfulness sessions led by our team of expert instructors. Classes will be added each week covering subjects from stress to sleep. Learn more.

Members experiencing anxiety or stress related to the COVID-19 pandemic can call the Optum/United Behavioral Health emotional support help line toll free at (866) 342-6892. This service is free, open to anyone and available 24/7. Information and resources are also available at liveandworkwell.com.