Plan Documents & Eligibility

In relation to honoring not excluding testing costs etc. without formal Plan Amendments, Amalgamated Life will follow the rules of the underlying plan document.

However, they will still need to be advised of any changes to the Plan document and Plan provisions. Amalgamated will apply a 60 day limitation to retroactively notify them of a change in the plan provisions

If a Plan needs to be amended or the state requirement mandates an amendment, the changes will be accepted in writing with commitments of a plan amendment asap at the end of the state of emergency. The day limitation to retroactively notifying them of a change in Plan provisions still applies.

Layoffs & Furloughs

As it relates to what happens to a Policy if a client lays off some of a work force due to COVID-19, Amalgamated will not enforce the change in membership provision in all coverages that have said provision. If all are laid off, as long as premium is being remitted on behalf of these individuals and the underlying Plan is continued, the policy will remain in effect.

COBRA EEs & Return to Work

If an employee is laid off and returns to work after not electing COBRA, waiting periods would be determined and imposed by the Plan Document. Amalgamated Life would follow the underlying Plan Document.

During COVID-19 crisis, Amalgamated agrees not to re-underwrite the laid-off employees as they return to work. Standard renewal underwriting procedures will be followed.

COBRA Extension Guidelines

Our general stance is that we will comply with all state and federal mandates but any plan changes must be communicated in advance in writing.

Actively at Work & No Scheduled Shifts

If the plan sponsor maintains coverage for these employees under the plan, they would be covered under the stop loss contract. Amalgamated Life needs to be notified of these eligibility exceptions during the crisis, as well as at time of claim if the claimant is to be considered eligible by the plan.

It would be in the policyholder's best interest to amend the plan even if temporary. Amalgamated will apply a 60 day limitation to retroactively notify them of a change in the plan provisions.

Policy Administration & Wet Signatures

Amalgamated will forgo “wet” signatures on policy forms, applications etc. and use confirmation emails until such time as people get back to work.

However, Amalgamated Life will require two separate authorizations via email with the attachments included, or a confirmation via phone call.

Claims Reimbursements & Timely Filing

As it relates to paying claims without some documentation that would normally be received due to effected entities, Amalgamated Life will continue to adhere to the current processes and applicable rules as they existed prior to this COVID-19 outbreak. However, timely claim filing requirements will be waived for up to 60 days, or longer if required by law or regulation.

Grace Periods

Amalgamated Life will follow all federal and state mandates that address catch up on premiums and extensions of grace periods.

Frequently Asked Questions

Amalgamated Life Insurance Company COVID-19 Questions and Answers
April 7, 2020

At Amalgamated Life Insurance Company, we are closely monitoring the impact of COVID-19 and are committed to supporting our clients during these uncertain times.  We are striving to be as flexible as possible but we must abide by state and federal regulations.  Please take the opportunity to read the below list of questions and answers on how we are currently handling exceptions during this pandemic.

Plan document and eligibility questions - Stop Loss

  • Will you as a carrier honor not excluding testing costs etc. without doing formal plan amendment or would we have the ability to do a retroactive plan document amendment at the conclusion of the crisis.  How will other and potentially future government mandates be handled?
    • Response:  Amalgamated Life Insurance Company will follow the rules of the underlying plan document.  However, we will need to be advised of any changes to the plan document and plan provisions.  We will apply a 60 day limitation to retroactively notify us of a change in the plan provisions.
    • We will honor not excluding testing costs etc. without doing a formal plan amendment, however this must be administered by the plan for all covered individuals as we do not administer 1st dollar claims.  We will apply a 60 day limitation to retroactively notify us of a change in the plan provisions.
  • For any other plan changes that may be occurring to deal with this crisis, would you accept these changes in writing without a signed plan document change until the end of this state of emergency?
    • Response: If the need to amend the plan or the state requirement mandates etc. the changes will be accepted in writing with commitments of a plan amendment as soon as possible.  We will apply a 60 day limitation to retroactively notify us of a change in the plan provisions.
  • What happens to a policy if a client lays off more than 10% of my work force due to COVID-19?
    • Response: During the crisis, we will not enforce the change in membership provision in all our coverages that have this provision.
  • What happens to a policy if a client has to lay off or furlough all of my work force due to COVID-19?
    • Response: If premium is being remitted on behalf of these individuals and the underlying plan is continued, then the policy will remain in effect.
  • Would a waiting period or new underwriting guidelines apply for any current employees who were laid off, then return to work if they do not choose Cobra?
    • Response:  Waiting periods are determined and imposed by the plan document.  We would follow the underlying plan document.  During the crisis, we agree not to re-underwrite the laid off employees as they return to work. Standard renewal underwriting procedures will be followed.  
  • How would you view claims from employees who are not actively at work because they have no scheduled shifts?
    • Response:  If the plan sponsor maintains coverage for these employees under the plan, they would be covered under the stop loss contract.  Amalgamated Life Insurance Company needs to be notified of these eligibility exceptions during the crisis, as well as at time of claim if the claimant is to be considered eligible by the plan. It would be in the policyholder’s best interest to amend the plan, even if temporarily.  We will apply a 60 day limitation to retroactively notify us of a change in the plan provisions.
  • Will clients need to amend plan documents to include a temporary layoff provision if one does not exist or could this be done retroactively?  These employees are typically not being terminated but are essentially being furloughed until their business can re-open.  Most of our client employers seem to want to be able to continue coverage without interruption during this time. 
    • Response:  If the plan sponsor maintains coverage for these employees under the plan, they would be covered under the stop loss contract.  Amalgamated Life Insurance Company needs to be notified of these eligibility exceptions during the crisis. We will apply a 60 day limitation to retroactively notify us of a change in the plan provisions.
  • If a Stop Loss client adds a mid-year open enrollment to their plan, will you cover those individuals under your Stop Loss policy?
    • Response:  Individuals who previously waived coverage in any of the plan sponsor medical plans and enroll during the special open enrollment period will not be considered eligible under the Stop Loss Policy.
    • The plan sponsor can cover them in the self-funded plan but their claims will not be considered eligible under our stop loss policy. The decision is based on the fact that our reinsurer will not cover these individuals. We also suggest you seek outside counsel, as this may also be a violation of Section 125 regulations.
  • Are you willing to make any adjustments to the right to change any Specific Premium or Aggregate Premium Rates and Monthly Aggregate Factors and the Minimum Annual Aggregate Deductible provisions in the Stop-Loss policy based on decreases in enrollment that may occur as a result of COVID-19?
    • Response:  We understand that many employers are looking for additional flexibility as a result of the Covid-19 pandemic. In response, we are adjusting our threshold regarding our right to re-calculate and the Minimum Annual Aggregate Deductible provisions. For 1/1/2020-4/1/2020 effective date cases, decreases in enrollment of up to 15% of covered lives that occur between 3/1/20 and the policies' renewal date will not be subject to mid-policy period recalculations of rates, deductibles, or factors as a result of the change.  For 1/1/2020 cases that have decreases in enrollment greater than 15%, please refer to the provisions included in the stop loss policy. For cases with 5/01/2020 effective dates, moving forward policy thresholds will be amended on a case by case basis at time of renewal.
    • We will also amend our Minimum Annual Aggregate Deductible provisions to reflect up to a 15% decrease in enrollment from 4/1 forward.
    • Please note decreases in enrollment include only those employees whose coverage under the plan has been terminated and not enrolled in COBRA. In order to address specific client situations please contact your carrier representative.
  • Can you confirm that you are willing to be compliant with all emerging state mandates regarding health benefit plans that may impact stop loss policy administration, even if you are not releasing a state specific update to the market? 
    • Response:  If the mandate is inclusive of Stop Loss policies then yes. 
  • It appears that at least a few of the BUCA administrators are now waiving cost shares for inpatient hospital admissions on the their fully insured business and giving the option to self-funded side as well.  https://www.modernhealthcare.com/insurance/aetna-waives-cost-sharing-covid-19-inpatient-hospital-admissions.  If a policyholder agrees to this change how will your stop loss policies react? What type of prior notification do you need if a client chooses to implement this policy?
    • Response:  Amalgamated Life Insurance Company needs to be notified of these changes in plan design and eligibility rules. It would be in the policyholders' best interest to amend the plan even if temporary. We will apply a 60 day limitation to retroactively notify us of a change in the plan provisions.
  • For clients that offer multiple plan designs. Would the carrier be open to allowing a special period in which enrolled individuals were given the opportunity to change plans mid-year?  The purpose of this is for people on low deductible high co-insurance plans to be able to choose a more cost effective plan for them. For example: a high deductible health plan. 
    • Response:  Amalgamated Life Insurance Company needs to be notified of these changes in plan design and eligibility rules. It would be in the policyholders' best interest to amend the plan even if temporary.

                   We will apply a 60 day limitation to retroactively notify us of a change in the plan
                   provisions. We will still be governed by state and federal mandates.

Policy Administration

  • During this time, can we forgo “wet” signatures on policy forms, applications etc. and use confirmation emails until such time when people get back to work and we can get “wet” signatures to you?  
    • Response: We can forgo “wet” signatures on policy forms, applications etc. and use confirmation emails until the time that people get back to work.  However, we will require two separate authorizations via email with the attachments included or a confirmation via phone call.

Claims

  • Is there a possibility of paying claims without some documentation that we would normally receive directly from either an employer or other effected entity?  For instance, if an employer has trouble getting hard copies of eligibility information etc., could we follow a pay and pursue type plan, which would allow us to get that information once people start back to work?
    • Response: We will continue to adhere to our current processes and applicable rules as they existed prior to this coronavirus outbreak.  However, we will waive timely claim filing requirements for up to 90 days, or longer if required by law or regulation (see below).
  • If your policy has a timely filing limit, will you agree to extend those limits until after the end of this crisis?
    • Response:  We will agree to extend the timely filing limits for up to 90 days and will adhere to individual state mandates as they change.
  • Are you implementing any other changes in claims handling policies during this time?
    • Response:  No, we are not changing our current claims handling policies but we will continue to monitor and follow state and federal mandates as necessary.

Ancillary and Voluntary/Worksite Benefits

  • If an employer furloughs their employees, and there is a claim, will this claimant be covered? This is if they continue to pay the premium for Basic Life/AD&D, STD, LTD etc.
    • Response: For Traditional Group Life and STD LTD-If the employer maintains coverage for these employees under the plan, they would be covered Amalgamated Life Insurance Company needs to be notified of these eligibility exceptions during the crisis. 
  • In regards to the above, how will the Voluntary Life/AD&D be handled?    Will you extend the policy premium grace period for groups and individuals? Can they catch up on premiums on their return to work?
    • Response:  Our voluntary/worksite products are paid for by the members.  The member will need to continue premium payments in order to keep the coverage inforce. We will follow all federal and state mandates that address catch up on premiums and extensions of grace periods.
    • Note: Our voluntary products are individual policies and portable at the same cost and coverage.  Members can directly pay for these policies should payroll deductions cease
    • With respect to our Group Life/AD&D and Group Disability products, we can extend the grace period to 90 days for your payment of premiums and the exercise of your rights under your policy.  This grace period will be inclusive of any existing grace period under your insurance policy.  We will waive all late payment fees otherwise due, and will not report late payments to credit agencies during this grace period.  You can repay any premiums that are due but not paid during this 90 day grace period in 12 equal monthly installments starting after the expiration of the grace period, or on such other terms mutually agreed upon.
  • What would happen if an employer closes and they had Critical Illness and/or Individual Disability coverage? 
    • Response:  The individual would remain covered as long as premium continues to be paid; For Individual Disability we will pay the claim based on based on policy limitations and their occupation prior to the furlough or layoff.
  • What happens if a covered individual has tested positive to the coronavirus and is quarantined?  Would they be covered for an Individual Disability claim?
    • Response:  The individual would remain covered as long as premium continues to be paid. Any claim resulting from this incident would be covered based on policy limitations.        
  • Will you extend the timely filing of claims requirement?
    • Response:  We will agree to extend the timely filing limits and will adhere to individual state mandates as they change.

For more information:
If you have any questions about these actions, please contact your SLIS representative.

Amalgamated Life Insurance Company has been helping America’s workforce and plan sponsors since 1943, delivering financial protection with its high quality, affordable group insurance, medical stop loss and voluntary benefits, provided with excellent customer service and fiscal integrity as evidenced by our consistent A.M. Best “A” (Excellent) ratings.

This document is subject to change; you should follow all state mandates where applicable and should rely upon the advice of your own counsel.