Plan Documents & Eligibility

If a plan is amended to allow for testing or treatment costs for COVID-19 to be covered as preventative with no cost share, Sun Life will not require that the plan amendment be sent to them for approval. This includes telemedicine services. While such changes could trigger the Right to Rerate provision in the policy, we will not make any adjustment to premium rates, deductibles, or factors as a result of these specific changes.

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 as long as premium for them continues to be paid.

Sun Life will not require that an amended Plan document permitting such continued coverage be sent to Sun Life for approval. However, in order to process claims accurately, Sun Life needs to be made aware of any such plan changes as soon as possible. Please send the amended plan document to your SLIS representative.

Sun Life is allowing groups to extend this eligibility through the end of their plan year, which would be through 12/31 for 1/1 accounts. We are requiring an email from the group documenting the change they are making to their eligibility be sent to our claims inbox at stop.loss.claims@sunlife.com. We require this documentation email for any
change in their eligibility, regardless of if a group is only extending coverage through 4/30, 7/31, or 12/31, etc. We are asking any change be properly documented just like we would normally require an amendment for any change.

Layoffs & Furloughs

If a business is closed due to COVID-19, Sun Life will consider employees who were actively-at-work the day before the closure to be eligible under the plan through April 30th, 2020, at which time Sun Life will determine whether to extend this date.

Actively at Work & No Scheduled Shifts

Sun Life will promptly pay all valid claims in which an eligible member has a qualifying and documented medical event, including an event related to COVID-19.

If an employee tested positive for COVID-19 and is quarantined and unable to work, the employee is considered totally or partially disabled during the period of medically required confinement. If the employee is quarantined but their symptoms allow them to perform work duties from home, the employee would generally not be considered totally or partially disabled, and would be considered actively at work.

As it relates to employees not actively at work because they have no scheduled shifts, Sun Life knows that employers may need additional flexibility as a result of 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 as long as premium for them continues to be
paid. Sun Life will not require that an amended plan document permitting such continued coverage be sent to Sun Life for approval. However, in order to process claims accurately, Sun Life needs to be made aware of any such plan changes as soon as possible.

COBRA EEs & Return to Work

As it relates to a required waiting period if an employee is rehired and had not elected COBRA, Sun Life knows that employers may need additional flexibility as a result of 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 as long as premium for them continues to be paid. We will not require that an amended plan document permitting such continued coverage be sent to Sun Life for approval. However, in order to process claims accurately, Sun Life needs to be made aware of any such plan changes as soon as possible. Please send the amended plan document or an email detailing the changes to our SLIS representative.

When an employee elects to continue coverage through COBRA, eligible claims for the employee and covered dependents will continue to be covered under the Stop-Loss policy as long as COBRA premiums are paid and the employee remains covered under the plan. This applies whether COBRA premiums are paid by the employee or another party on the employee’s behalf.

Policy Administration & Wet Signatures

As it relates to the need for 'wet' signatures, Sun Life understands that not everyone has the capability to print, sign, and scan documents for return to Sun Life when working remotely. Where possible, Sun Life would ask to leverage e- Signature functionality.

If you or your client do not have eSignature capability, Sun Life will temporarily consider accepting paperwork without signature provided there is a clear audit
trail. This will be through at least April 30, 2020, at which time Sun Life will determine whether to extend the date.

There must be a clear e-mail from the client and the broker indicating they wish to move forward with writing new business / renewing with Sun Life Signed paperwork will be required at the earliest opportunity. Sun Life's account management team will work with SLIS and the client on the follow up plan.

Claim Reimbursements & Timely Filing

Claims can be filed up to 12 months after the end of the Claims Basis during which the claim arose.

For example, for a 1/1/20 policy that has a 12/12 Claims Basis, claims incurred and paid between 1/1/20 and 12/31/20 can be submitted through 12/31/21 (12 months after the end of the Claims Basis).

For a 1/1/20 policy that has a 12/15 Claims Basis, claims incurred between 1/1/20 and 12/31/20 and paid between 1/1/20 and 3/31/21 can be submitted through
3/31/22 (12 months after the Run-Out period).

Early Rx Refills

Sun Life will reimburse costs related to early refills through at least June 30, 2020, at which time they will determine whether to extend that date.

Rate or Coverage Change

Sun Life knows that employers may need additional flexibility as a result of COVID-19. As a result, Sun Life is adjusting the process around the Right to Recalculate provision (continued on next page).

Decreases in enrollment of up to 30% of covered lives that occur between 3/1/20 and 12/31/20 will not be subject to a recalculation of rates, deductibles, or factors
as a result of such a change.

For decreases in enrollment greater than 30%, please refer to the provisions included in the Stop-Loss policy.

Decreases in enrollment include only those employees whose coverage under the plan has been terminated and who have not enrolled in COBRA coverage.

If changes in staffing that were necessary based on COVID-19 lead to covered employees falling below the minimum number of lives stated in the Stop Loss policy, Sun Life is open to working with clients on a case-by-case basis to help them understand the flexibility Sun Life may be able to provide.

Special Enrollment Periods

Sun Life has received questions from employers regarding special open enrollment periods due to the COVID-19 pandemic.

At this time, Sun Life is not considering approving such requests, but will continue to monitor the situation. If legislation is passed requiring self-funded plans to offer a special open enrollment period, Sun Life will provide additional guidance at that time.

It is important to note that employees who have dependents who experience a loss of medical coverage with the dependent’s employer may be able to enroll in the employee’s plan outside the standard open enrollment period depending upon the plan terms.

For example, if an employee’s dependent had medical coverage through his or her employer and lost it due to a change in employment status, the dependent may be eligible to enroll in the employee’s plan based on that qualifying event.

If the dependent is eligible to enroll in the employee’s plan and does so, expenses incurred by the dependent would be eligible for reimbursement under the Stop-Loss policy.

Employees who are covered as a dependent under their spouse’s employer plan who lose coverage because the spouse lost coverage may be able to enroll (along with any dependents) in their employer’s plan outside the standard open enrollment period according to the language in the underlying plan.

If the employee, along with any dependents, is eligible to enroll in the employer’s plan and does so, expenses incurred by the employee and the dependents would be eligible for reimbursement under the Stop-Loss policy.

In addition, several states are considering special open enrollment periods for plans offered through marketplace exchanges that may provide options for uninsured individuals.

Grace Period Extensions

Given the disruption due to COVID-19, Sun Life is extending the standard policy grace period for an additional 30 days if needed.

There is no need to contact Sun Life as the grace period is being extended and applied to groups automatically.

COBRA:

If an employer decides during the current Stop-Loss Policy year to amend its plan to extend the grace period for COBRA premium payments and the COBRA administrator allows the change, we will support an extension of the grace period of up to 30 additional days. We will not require that the plan amendment be sent to us for approval and such a change will not trigger the Right to Recalculate provision in the Policy. In order to process claims accurately, we need to be made aware of any such plan change as soon as possible. Please send an email detailing the change or a copy of the plan amendment to our claims team at Stop.Loss.Claims@sunlife.com. Prior to renewing your Stop-Loss Policy, we will require a copy of the plan amendment.

Monthly Aggregate Accommodation

Sun Life will consider requests for mid-year policy changes such as adding monthly accommodation on a go-forward basis.

Telemedicine & Virtual Visits

What if we are adding telemedicine services for the first time to the Plan or expanding telemedicine (such as including specialty services and mental health)? Will you require an updated plan document be sent to you for approval? Will you make mid-policy year rate adjustments based upon such changes?

Our goal is to support employees and employers through this difficult time. We support plan changes that increase access or add access to telehealth/telemedicine solutions. If your plan is amended during the current Stop-Loss Policy Year, we will not require that the plan amendment be sent to us for approval and will not change your premium for the current Policy Year based upon such changes. However, in order to process claims accurately, we need to be made aware of any such plan changes as soon as possible. Please send an email detailing the changes or a copy of the plan amendment to our claims team at Stop.Loss.Claims@sunlife.com. Prior to renewing your Stop-Loss Policy, we will require a copy of the plan amendment.

Waiting Periods

If an employer amends its plan during the current Stop-Loss Policy Year to waive or reduce waiting periods for all employees who are in a waiting period or for previously covered employees returning to work in order to provide them with coverage under the plan, such employees will be considered covered under the Policy.

We will not require that the plan amendment be sent to us for approval and such changes will not trigger the Right to Recalculate provision in the Policy. However, in order to process claims accurately, we need to be made aware of any such plan changes as soon as possible. Please send an email detailing the changes or a copy of the plan amendment to our claims team at Stop.Loss.Claims@sunlife.com. Prior to renewing your Stop-Loss Policy, we will require a copy of the plan amendment.

Minimum Lives

We understand the COVID-19 (Coronavirus) crisis may result in temporary staffing changes for some businesses that cause the plan to fall below the minimum number of participants stated in the Stop-Loss Policy.

We will evaluate enrollment over the course of a several month period to allow time for COBRA elections to be made so that they can be counted toward plan enrollment or for potential rehiring to occur.

Testing and Treatment

There are no pandemic related provisions or exclusions in our Stop-Loss Policy. Expenses related to testing and treatment of COVID-19 (Coronavirus) will be covered under the Stop- Loss Policy as long as they are covered under your plan and meet the Policy terms as with any other claim.

Further Info on COVID-19 Drugs

If an employer decides during the current Stop-Loss Policy year to amend its plan to extend the grace period for COBRA premium payments and the COBRA administrator allows the change, we will support an extension of the grace period of up to 30 additional days. We will not require that the plan amendment be sent to us for approval and suIf a drug is approved by the FDA to treat COVID-19 and an employer amends its plan during the current Stop-Loss Policy Year to approve the drug, we will not require that the plan amendment be sent to us for approval and such a change will not trigger the Right to Recalculate provision in the Policy. Any such change should be reflected in the drug formulary/plan document prior to the Policy being renewed.ch a change will not trigger the Right to Recalculate provision in the Policy. In order to process claims accurately, we need to be made aware of any such plan change as soon as possible. Please send an email detailing the change or a copy of the plan amendment to our claims team at Stop.Loss.Claims@sunlife.com. Prior to renewing your Stop-Loss Policy, we will require a copy of the plan amendment.

Providing access to alternative medications for employees who might experience challenges in obtaining a needed drug as a result of it being used to treat COVID-19 is a critical concern. Employers should contact their Pharmacy Benefit Manager and/or medical claim administrator to understand their options and the costs associated with making such changes.

If your Plan is amended during the current Stop-Loss Policy Year to allow costs relating to a replacement drug to support on-going treatment, the costs will be considered eligible under the Stop-Loss Policy. We will not require that the plan amendment be sent to us for approval and the change will not trigger the Right to Recalculate provision in the Policy. However, in order to process claims accurately, we need to be made aware of any such plan changes as soon as possible. Please send an email detailing the changes or a copy of the plan amendment to our claims team at Stop.Loss.Claims@sunlife.com.

Further Info on COVID-19 Drugs

If a drug is approved by the FDA to treat COVID-19 and an employer amends its plan during the current Stop-Loss Policy Year to approve the drug, we will not require that the plan amendment be sent to us for approval and such a change will not trigger the Right to Recalculate provision in the Policy.

Any such change should be reflected in the drug formulary/plan document prior to the Policy being renewed.

Providing access to alternative medications for employees who might experience challenges in obtaining a needed drug as a result of it being used to treat COVID-19 is a critical concern.

Employers should contact their Pharmacy Benefit Manager and/or medical claim administrator to understand their options and the costs associated with making such changes.

If your Plan is amended during the current Stop-Loss Policy Year to allow costs relating to a replacement drug to support on-going treatment, the costs will be considered eligible under the Stop-Loss Policy.

We will not require that the plan amendment be sent to us for approval and the change will not trigger the Right to Recalculate provision in the Policy.

However, in order to process claims accurately, we need to be made aware of any such plan changes as soon as possible.

FDA approved immunizations are considered preventative care and costs associated with them are covered under the Stop-Loss Policy. There will be no rate impact in the current Policy Year.

Additional Items of Note

A drug that becomes available to treat COVID-19, if covered by the underlying Plan and approved by the FDA, will not be considered experimental and investigational and expenses paid relating to it will be deemed an Eligible Expense.

FDA approved immunizations are considered preventative care and costs associated with them are covered under the Stop-Loss policy.

Utilization Management

Due to the COVID-19 crisis, the Department of Insurance in certain states has recommended that utilization management review and notification requirements be waived to lessen the burden on clinical support staff.

Under the circumstances, we support such a change through May 31, 2020 in any state where the Department of Insurance has recommended it, at which time we will evaluate the need for an extension.

Through May 31, 2020, such a change will not impact claim eligibility for reimbursement under the Stop-Loss Policy. Sun Life will issue additional guidance for expenses incurred after May 31, 2020.

Rate Guarantee

For employer-paid and employee-paid Group Benefits (Life, Long-Term Disability, Short-Term Disability, Dental, Vision, Cancer, Critical Illness and Accident), Sun Life will be continuing the inforce rate for 6/1, 7/1 and 8/1 renewals for twelve months.

This will be applicable for all groups with fewer than 500 lives (as determined by the highest currently enrolled SLF coverage).