American Fidelity will support the administrative plan change to cover COVID-19 testing costs etc., as currently mandated by the federal government (or state government, if more liberal). There will be no change to the stop loss rates or factors. AF would expect other future governmental mandates would be handled in the same way but, as always, does reserve the right to evaluate for additional stop loss policy exposure.
As it relates to Plan Document changes requiring signature - American Fidelity will be happy to review any plan change request on an expedited basis and determine if a Plan Amendment is required, or if the change is something that can be accepted on an administrative exception basis. American Fidelity will accept a signed Plan Document retroactively within 30 days as long as they have advance written notification and agreement. AF asks that Policyholders submit their previously approved Plan Amendments related to COVID-19 by September 1, 2020, unless specifically requested earlier.
As it relates to what happens to a policy if a client is forced to lay off or furlough a percentage or all of their workforce, both scenarios relate to continuation of coverage under the Stop Loss Policy. American Fidelity knows that employers may need additional flexibility surrounding COVID-19.
Employees whose eligibility under the plan is impacted by COVID-19 related actions can still be considered covered under the Stop-Loss policy during the current Policy Year provided premium continues to be paid for them. American Fidelity will not require that an amended Plan Document permitting such continued coverage be sent to them for approval. However, in order to process claims accurately and expeditiously, American Fidelity does need to be made aware of any such plan changes as soon as possible. Please send the amended Plan Document, when updated, to the AFA Underwriter for approval.
As it relates to waiting periods for current employees who had to be laid off and returned to work without choosing COBRA, American Fidelity would expect to
follow the Plan continuation provisions, but may consider waiving the waiting period depending on the length of period the employee was without coverage, or may request a short form health questionnaire if outside of an acceptable or mandated time frame.
American Fidelity will monitor both state and federal legislation surrounding the issue, as well.
As it relates to viewing claims from employees who are not actively at work because they have no scheduled shifts, American Fidelity would defer to the Continuation provisions of the Policyholder's plan document.
In lieu of wet signatures on Policy forms, applications, etc. during this time, American Fidelity plans to utilize DocuSign capabilities to gather electronic signatures. American Fidelity's policy team is prepared to work with clients closely on this endeavor to meet their customer needs during this difficult time administratively.
As it relates to paying claims without some documentation normally received due to difficulty obtaining such items during this time, American Fidelity would review on a case by case basis. Their intent is always to introduce some common sense solutions during challenging times wherever possible, to ensure customer's Stop Loss claims continue to be reimbursed promptly.
American Fidelity does not intend to change filing limits at this time, as they are generally considered very generous under the Stop Loss coverage. American
Fidelity is in close contact with State insurance departments, and will adapt their policy as directed. If there is any question or extended potential delay known by the employer or their representative, American Fidelity does ask that they send a provisional notice in order to add to the file when the claim is able to be filed appropriately.
As it relates to conformity with Governing Law (i.e. a provision of the Plan is contrary to any law to which it is subject) - where similar Plan provisions exist in a Policyholder's Plan Document, American Fidelity will not require a formal Plan amendment to reflect this law and there will be no effect on the Stop Loss rates or factors.
American Fidelity will reimburse costs paid by the plan for early refills of medication. A plan amendment is not needed at this time, but AF asks for an amendment for any changes that persist past September 1, 2020.
As it relates to administrators waiving cost shares for inpatient hospital admissions, American Fidelity asks to be made aware of any Plan changes during this time. AF will not require a formal Plan Amendment unless the change persists past September 1, 2020.
If a number of employees dramatically decreases as a result of COVID-19, American Fidelity will postpone any termination or rate change until at least September 1, 2020, as long as the employer maintains their self-funded health plan, and their stop loss premium is paid. American Fidelity will continue coverage as long as stop loss premiums are paid, until at least September 1, 2020, in situations where the employer cannot maintain minimum plan enrollment or has to temporarily stop business operations due to the COVID-19 emergency.
American Fidelity would consider allowing a special enrollment period in which enrolled individuals were given the opportunity to change plans mid-year if given proper notice and well-defined enrollment terms.
This would only apply to employees enrolled under one of the employer's current plan offerings. In the event of a significant enrollment shift to a plan option with enhanced benefits, AF would reserve the right to review in-force rates and factors.
American Fidelity's commitment to their customers is to follow any state department requirements to extend grace periods as they arrive. The policy already allows ample grace period timeframes, plus an additional 30 days for SLIS policies, and do not anticipate extending any further at this time.