Plan Documents & Eligibility

Voya will support covered members as defined by the Plan sponsor, including changes made to their plan document and/or employee leave policy related to COVID-19. Please notify Voya of changes as soon as possible. Voya will reevaluate position on plan changes once the post peak phase of the pandemic, as determined by the WHO (World Health Organization) has concluded, given that normal standard is 31 days advance notice.

Voya will extend the Material Change provision in the policy to allow for notification of any material change by an additional 30 days for those administratively impacted by COVID-19 until we determine such accommodations are no longer necessary.

This does not require an amended plan document to be submitted but, does require written notification of such changes. Please review your policy for additional information and notify your client manager of any material changes.

Layoffs & Furloughs

Voya standardly reserves the right to rerate the policy due to any material changes. This includes, but is not limited to, an increase or decrease in the number of Covered Persons and Covered Dependents that exceeds 15%.

Please review your policy for additional information and notify your client manager of any material changes. Voya will review employer specifics and determine if any rating impacts are necessary on a case-by-case basis.

In addition, It is ultimately the employer’s responsibility to determine eligibility requirements for medical coverage.

If medical coverage is still being continued and paid for, specific to individuals who have been put on temporary furlough, temporary layoff, or other reductions as a result of COVID-19, those individuals will also remain covered under the employer’s Stop Loss policy.

However, to the extent such changes in eligibility result in a change in the number of covered persons under the stop loss policy it may constitute a material change as defined under the stop loss policy.

The Company will support covered members as defined by the plan sponsor including changes made to their plan document and/or employee leave policy related to the care of COVID-19. Please notify us of changes as soon as reasonably possible.

COBRA EEs & Return to Work

Generally speaking, if the employee is rehired within the same plan year and is not considered a new hire under the underlying plan, they would not need to satisfy a new specific deductible.

Please note the company would need to rely on the employer and/or their administrator to manage this from an eligibility and claim reporting perspective. Voya will follow any nondiscriminatory eligibility requirements defined by the plan sponsor.

Actively at Work & No Scheduled Shifts

There are no changes to our actively-at-work requirements. If the insured person is working from an alternative location at the direction of (or approved by) the employer, that would be considered actively-at-work.

Absence Management - If the employee has been diagnosed with COVID-19, they can take a leave of absence under FMLA, and any State leave entitlement provided they are eligible.

The employee must provide certification completed by their physician certifying to the dates of leave.

If the employee's child, spouse, or parent has been diagnosed with COVID-19, they could receive FMLA and State leave benefits with a completed certification.

If an employee has no symptoms, but is in quarantine, employers should not count this against FMLA leave as it does not meet the definition of a serious health condition from the Department of Labor.

Employers can consider allowing an accommodation to work from home, if the 14-day quarantine timeframe is required.

Claim Reimbursements & Timely Filing

Voya’s standardly requires that proof of loss for a claim be provided no later than 180 calendar days after the end of the coverage period. Claim proof of loss filing periods will be extended by an additional 30 days for those administratively impacted by COVID-19 until Voya determines such accommodations are no longer necessary.

For example, for a policy effective 10/1/2018 with a paid contract period, normally proof of loss would be required by 3/31/2020. Voya will extend the proof of loss period to 4/30/2020. If a client anticipates having any issues with being able to provide timely proof of loss due to the circumstances surrounding COVID-19, please contact your client manager.

As it relates to paying claims without some documentation standardly provided due to it being an affected entity, Voya will consider these requests on a caseby- case basis. In addition, claim proof of loss filing periods will be extended by 30 days for those administratively impacted by COVID-19 until we determine such accommodations are no longer necessary. For example, for a policy effective 10/1/2018 with a paid contract period, normally proof of loss would be required by 3/31/2020. We will extend the proof of loss period to 4/30/2020. If you anticipate having any issues with being able to provide timely proof of loss due to the circumstances surrounding COVID-19, please contact your client manager.

Early Rx Refills

Voya will allow the following to apply under the stop loss coverage as required by the “Families First Coronavirus Response Act”. No prior notification to Voya is required.

Early refills of medication to ensure participants have a 30-day supply.

Cost Share

Voya will allow the following to apply under the stop loss coverage as required by the “Families First Coronavirus Response Act”. No prior notification to Voya is required.

Waiver of health plan deductibles, co-pays and cost sharing on covered participants for COVID-19 testing.

If any testing fees or expenses related to COVID-19 are considered eligible expenses under the employer's Plan, they will be considered eligible under the Stop Loss Policy. This includes waiving deductibles, co-pays, and co insurance.

"Any expenses will be considered eligible under the company’s Stop Loss policy as long as those expenses are eligible under the employer’s plan. This also includes waiving health plan deductibles, co-pays, coinsurance, virtual visits, telemedicine and, early refills of medication to ensure participants have a 30-day supply will also apply.

If these expenses were not covered under the plan at the time of underwriting and the employer is making a mid-year plan change, this does not require an amended plan document to be submitted but, does require written notification of such changes.

As stated in our Policy, Voya must be notified of any Material Changes within 31 days. Voya will extend the Material Change provision in the policy to allow for notification of any material change by an additional 30 days for those administratively impacted by COVID-19 until we determine such accommodations are no longer necessary. Please review your policy for additional information and notify your client manager of any material changes. We will not rerate or change aggregate factors, premium or coverage under the stop-loss policy solely as a result of this change."

Rate or Coverage Changes

Voya standardly reserves the right to rerate the policy due to any material changes. This includes, but is not limited to, an increase or decrease in the number of Employees that exceeds standard percentages noted in your policy. Please review your policy for additional information and notify your client manager of any material changes. Voya will review employer specifics and determine if any rating impacts are necessary on a case-by-case basis.

Grace Period Extensions

Voya standardly includes a premium grace period of at least 45 days in the Policy. Grace periods for premium due in this time period will be extended an additional 30 days for those administratively impacted by COVID-19 until Voya determines such accommodations are no longer necessary. For example, for premium due 6/1/2020 with a 45 day grace period through 7/15/2020, we will extend the grace period to 8/14/2020.

If a group anticipates having any issues with being able to remit premiums due to the circumstances surrounding COVID-19, the client contact manager must be notified.

Special Enrollment Periods

Voya will consider open-enrollment requests on a case-by-case basis. The employer should reach out to their Voya Client Representative for assistance.

Stop Loss Summary

The Stop Loss Policy covers any expenses or fees that arise from testing, medical treatment, or other claims related activity that could be incurred - as long as those same costs are considered eligible expenses under the employer's medical Plan Document.

Therefore, if COVID-19 is an eligible expense under the employer's Plan document, any claims incurred will be eligible.

This can include waiving deductibles, co-pays, coinsurance, virtual visits, and telemedicine.

In addition, early refills of medication to ensure participants have a 30-day supply will also apply.

Furthermore, Voya will support covered members as defined by the Plan sponsor should plan changes be made as a result of COVID-19.

Please notify your SLIS representative of changes as soon as reasonably possible.

Voya will reevaluate position on plan change notification in conjunction with ongoing guidance and developments as determined by the WHO, given that Voya's normal standard is 31 days advance notice.

COBRA Extension Guidelines

In response to the joint guidance issued by the DOL/IRS on April 29, 2020, Voya has reviewed and will comply with the requirements.

From a Stop Loss perspective, these changes pose additional risk that is difficult for us to quantify at this time. Some of our concerns include the opportunity for adverse risk selection, the fact that these changes apply to all individuals (not just those impacted by Covid-19), and the unknown timing of the end of the Covid-19 National Emergency.

In order to assist with our continued review of the new guidelines, it would be helpful if you could provide any insight as to how are employers and/or benefits administrators are planning to manage these changes and what kind of reporting or back-up will we be able to receive at time of claim.

While we will not require an amendment specific to the new guidelines, an amendment or written notification may be required if the employer is implementing any other material changes as a result of the new guidelines. Examples include, but are not limited to:

  • Any other temporary or permanent changes being made related to the new guidelines
  • Whether or not coverage will remain inforce post pandemic
  • Confirmation that coverage being extended is subject to the rest of the current policy provisions
  • Changes to employer contributions


The employer should contact their Voya Client Representative with any questions.