Recertification
Annual Proof that you’re in compliance with
participation rules
Insurance Companies may enforce their participation rules and the new Health Reform definition of small employer needing at least one bonifide non spousal employee when you 1st apply.
On the other hand, there is a Special Enrollment from November 15th to December 15th, when an employer can enroll without having to meet participation or contribution requirements. One would have to check with each company to see if they would do an audit at renewal.
Here’s some information on what Renewal enforcement might consist of:
Renewal questionnaires are sporadic with most companies, with Cal Choice almost always requiring recertification.
For more details check the Administration page for the Insurance Company you are with.
UHC United Health Care
Participation Audit
Do you have a high enough percentage of employees covered?
Are you a bonified business?
- Our UHC – United Health Care Administrative Page
- UHC's Web Page on Eligibility Verification
- Our Webpage on Common Ownership -
- UHC Common Ownership Certification Form
- Employer Information Form UCH
- Our Webpage on Common Ownership -
- UHC's Web Page on Eligibility Verification
Questions about your Eligibility Audit?
Kaiser Recertification Booklet
Rev May 2019
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Hi Steve –
I may have to lay off some of my employees or cut their hours – including mine, because of the COVID 19 & Quarantine.
If I cut my hours or have no hours altogether, and continue paying the Kaiser medical insurance, am I or any of my laid off employees still covered as long as continue to pay the insurance?
Kind Regards,
Ruth
The first thing to check and ask, is how many hours?
Under Health Care Reform 30 hours is full time.20 hours for part time.
I need to double check. Since you are with Kaiser, it appears that they automatically include Part Time 20 hours and don’t ask you to make a choice on their application. If so, any employees still working 20 hours don’t have an issue.
I will email you privately the last Kaiser Employer Application we have for you.
We’ve only received a bulletin on this issue so far from Blue Shield.
We will post any further guidance here. See also our page on how Insurance Companies are handling claims & testing for Corona Virus.
Eligibility and billing questions
Question:
Will Blue Shield of California continue to enforce active at-work provisions for fully insured employer groups that have reduced their workforce or workforce hours?
Answer:
The terms of our group service agreements continue to apply to employee eligibility for coverage. Please refer to the agreement and note that there are provisions in most group service agreements that may allow for continued coverage for members who are impacted by a temporary suspension of work or temporary reduction of hours in certain circumstances, such as a layoff, furlough, or approved leave of absence. This may be permitted under the employer’s policies regarding coverage, under the following conditions:
Please also note that employees who lose eligibility for coverage due to a reduction of hours or suspension of work may have the right to continue coverage under COBRA or Cal-COBRA. Please refer to your group service agreement for additional information.
Question:
For groups in industries affected by COVID-19 closures, will Blue Shield of California provide a grace period other than the usual 30 days for premium billing?
Answer:
We are evaluating every decision or request from the State and Federal Government and our senior sales leaders are meeting daily to make proposals and decide on next steps.
For now, we’re referring all clients back to their existing contracts and highlighting provisions [see our page on how to read an EOC Evidence of Coverage] that help in a time like this. https://mrktoa.blueshieldca.com/200323_broker_newsletter_t4.html#article5
FAQ from Gallagher
24. If we use a measurement/stability period safe harbor, which hours do we have to count when calculating the number of hours worked in the measurement period?
For hourly employees, you must calculate actual hours of service and hours for which payment is made or due for vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military duty or leave of absence.
For non-hourly employees, you are permitted to calculate the number of hours of service using one of three methods. You may apply different methods for different classifications of non-hourly employees, so long as the classifications are reasonable and consistently applied.
The three methods are:
However, you cannot use the days-worked or weeks-worked equivalency method if the result would be to substantially understate an employee’s hours of service (e.g. employees working three 10-hour days).
Excerpt of Bulletin from CA Department of Insurance
What if I cannot pay my insurance premiums?
The Department of Insurance is Requesting a 60-day grace period to pay insurance premiums
Consumers should contact their insurance company if they need additional time to pay their premium.
http://www.insurance.ca.gov/0400-news/0100-press-releases/2020/release030-2020.cfm
http://www.insurance.ca.gov/0400-news/0100-press-releases/2020/upload/nr030-BillingGracePeriodNotice03182020.pdf
http://www.insurance.ca.gov/01-consumers/140-catastrophes/Coronavirus.cfm
Here’s, hot off the press!
Q:Can an employee who loses eligibility (e.g. hours reduced, furloughed employee, etc.) retain eligibility if I (the employer) still pays employer contributions?
A: For large and small groups:
• As long as the group and employee are current on their monthly payments, Kaiser Permanente will allow employees that would otherwise have lost eligibility to remain on the plan.
• Kaiser Permanente reserves the right to change this policy at any time.
Aetna’s FAQ for groups 100+ and self insured
Small Group 2 – 100
In reviewing your Kaiser EOC Evidence of Coverage – it’s up to the employer to make the rules for who is eligible!
Group eligibility requirements
You must meet your Group’s eligibility requirements, such as the minimum number of hours that employees must work. Your Group is required to inform Subscribers of its eligibility requirements.
Nope, it’s not that simple. See page 13 of the 2019 Group Administrators Handbook. Kaiser’s rules go back to what is required under Health Care Reform- Employee Definition – see above.
On the other hand:
Also in the EOC, under SPD disclosure section:
The EOC does not explain in detail Group’s eligibility requirements (other than the Health Plan eligibility requirements that appear in the “Premiums, Eligibility, and Enrollment” section).
The plan administrator must include Group’s eligibility information in the Group’s SPD Summary Plan Description
Note:
Health Plan does not impose preexisting condition exclusions or waiting periods, or require that employees be actively at work at the time of enrollment. Therefore, the EOC does not contain a notice of preexisting condition exclusions, waiting periods, or actively-at-work requirements.
Google research on definition of actively at work
The prohibition of actively-at-work clauses is part of the HIPAA nondiscrimination rule’s effort to protect employees from discrimination based on a health factor. https://www.onedigital.com/blog/correctly-administer-actively-work-clause/
***I believe they are talking about the employees health… On the other hand we are all quarantined because of whose health?
Mayor Garcetti of Los Angeles said Department of Water and Power will shut off services for the businesses that don’t comply with the “safer at home” ordinance. https://ktla.com/news/coronavirus/mayor-garcetti-expected-to-hold-daily-briefing-on-l-a-s-covid-19-response/
Mayor Garcetti Video update 3.24.2020 & written summary
Stay at Home Order 3.21.2020 County of LA
Safer at Home FAQ’s
Guidance from Sequoia on changing documents to comply and avoid “actively at work” issues. https://www.sequoia.com/2020/03/benefits-continuation-during-a-furlough/
Considering the Governor & Insurance Commissioner ordered all insurance companies to pay for Corona Virus testing at no co pay or deductible
All the Insurance Companies – issuing bulletins on how great they are at getting you testing, coverage and how to protect yourself. See link above for our Corona Virus page.
Covered CA opened up a Special Enrollment to allow anyone without Insurance to buy it now!
I just can’t see the group carriers cancelling coverage!