This is Part V of our COVID-19 Q&A series. We're gonna be talking about health insurance applications over the coronavirus, including layoffs and furloughs. We're going to talk about specific coverages that are being offered new enrollment periods, all kinds of fun stuff. As we dive in or before we do, do me a favor, please subscribe. It makes such a difference to our ability to continue to produce long-form free content like this. You can find us on iTunes, Google podcasts, Spotify, Stitcher, any pod catcher of your choice. Also if you subscribe at peopleprocesses.com we have subscriber only content, including sample communications that you can use to send out to your employees, edit them, run by your attorney if you'd like. And everything from communicating furloughs to how these benefits change or work. We want to help you communicate those, peopleprocesses.com to subscribe. 

Now let's dive right in. The first question and I apologize if I sound a little funny, I've got a really bad allergies here at the beginning of April, late March. It is not Coronavirus, but just quite allergic, I apologize.

First question we're getting which is a lot is, 

If our employees are no longer working, are they still entitled to group health plan cover? 

So what happens when I terminate someone or lay them off? The answer depends. The answer is, Not Necessarily. Are they entitled to group health plan coverage? You need to check your health plan document (or certificate of coverage if your plan is fully insured) to determine how long employees who are not actively working may remain covered by your group health plan. Most of the time, it's through the end of the month in which they are terminated or become ineligible due to an hour reduction. Once this period expires, active employee coverage must be terminated (unless the insurance carrier or self-funded plan sponsor agrees to temporarily waive this eligibility provision), and you must send your Cobra notice. If your plan is self-funded and you'd like to waive the coverage because you can, that's cool, but make sure that your stop-loss coverage carriers agree to cover claims related to participants who would otherwise be ineligible for coverage. That's a big deal. 

As of late March, many fully insured plans are WAIVING minimum hour requirements and generating a new special enrollment period. So if you're cutting someone who's full time down to 20 hours a week, normally, that would be a life event in their coverage on whatever day your plan document says. Normally, at the end of the month you do that. However, most of the fully insured companies, the large ones out there, HUMANA, Aetna, Cigna, United have decided, "Hey, you 're going to waive that minimum coverage requirement if you choose to do so. If you choose to do so you have to do it for everybody. Keep that in mind." And that would allow you to continue insurance for employees who've had major hour reductions. 

Well, that leads to the next question.

What happens to the group health plan coverage if employees are not working enough and unable to pay their share of premium?

In the normal everyday stuff, if they can't pay the premium, then group health plan coverage would cease when that employee's share premium is not timely paid. However, several actions might be taken that could allow coverage to continue. 

First, the insurance carrier providing the health coverage may voluntarily continue the coverage while this disaster is sorted out. Like I said, most of them have and until an employee reopens their doors. More likely, the employer will make an arrangement with the insurance carrier to provide health coverage to pay the employees' share premiums to keep coverage in place (at least temporarily) and that's actually what's going on. The insurance carriers are fine with the employer picking up a whole cost until the employer can reopen its doors or the employees...