FFCRA Employee FAQs

Since the Families First Coronavirus Response Act (FFCRA) was passed, many employees have had questions about how this impacts their health insurance, and what emergency paid leave and other relief options are available to them. Our team provided a webinar on April 9, 2020, to address most of these questions, with additional FAQs shared below.

What if the employee's income has been reduced due to COVID-19; would that count as a "qualifying event" (aka affordability) to change or cancel insurance?

Unfortunately, affordability isn’t a qualifying event that would trigger an open enrollment period for making changes to insurance. However, reduced income may qualify you for unemployment benefits to help you pay for premiums.

Does a reduction of hours (due to COVID-19) to a part-time employee count as a qualifying event to change or cancel insurance?

While a permanent change in employment status would trigger an open enrollment window, reduced hours due to the Coronavirus pandemic is not a qualifying event . Our carriers have updated their policy to allow for a 90-day reprieve for employees who have reduced hours. The employees will remain on the insurance policy and will not lose coverage due to loss of working hours. This applies to all Stratus.hr clients on our EMI Health plans and all other carrier policies. Clients should continue paying for health insurance to maintain benefits.

Employees who receive a reduction of hours may qualify for unemployment benefits, which could be used to help pay for premiums. Remember that all health insurance plans in the market will cover COVID-19 testing at 100%, and many are also waiving treatment. This is not a time to go uninsured!

If employees are laid off or no longer have a job, they may apply for COBRA and could use their COVID-19 stimulus payment to help pay for premiums. If the COBRA option is too expensive, they could look for a lower cost health plan in the individual insurance marketplace found at www.healthcare.gov.

What are the pros and cons of a doctor’s office being excluded from the emergency paid leave options available through the FFCRA?

With the updated definitions provided by the DOL, the term “healthcare provider” is determined at the employee level, not the organization as a whole. In other words, this isn’t something an entire company can choose to exempt itself from offering.

Question 56 of the DOL’s Questions & Answers regarding the FFCRA defines a health care provider as:

“…anyone employed at any doctor’s office, hospital, health care center, clinic, post-secondary educational institution offering health care instruction, medical school, local health department or agency, nursing facility, retirement facility, nursing home, home health care provider, any facility that performs laboratory or medical testing, pharmacy, or any similar institution, Employer, or entity. This includes any permanent or temporary institution, facility, location, or site where medical services are provided that are similar to such institutions…”

The DOL goes on to emphasize that employers be “judicious when using this definition to exempt health care providers” to “minimize the spread of the virus associated with COVID-19.” Simply put, this is a unique case-by-case decision where the employer decides whether or not an essential employee should be allowed to take the paid leave, based on their health and risk of spreading the virus.

How is EMI Health covering COVID-19?

Testing:
Members will not have any cost sharing (including copays, coinsurance, or deductibles) for COVID-19 testing as EMI Health will cover these costs 100%.

Treatment:
EMI Health will cover costs for COVID-19 treatment at 100% up to the plan's MAC for covered members who receive treatment between April 1, 2020 – May 31, 2020.

Members will not have any cost sharing (including copays, coinsurance, or deductibles) for COVID-19 testing or treatments as EMI Health will cover these costs 100%.

It is important to note that, while EMI Health will pay nonparticipating providers as if they were participating for COVID-19 testing and treatment rendered through May 31, 2020, nonparticipating providers may choose to balance bill the patient for amounts that exceed the plan's MAC. Participating providers have agreed to write off that amount and will not balance bill the patient.

Employees can find updated information at EMIHealth.com or visit their weekly updated blog at https://blog.emihealth.com/.