On May 11th, the federal government will end the Public Health Emergency and National Emergency periods related to COVID-19. These periods were initiated on January 27, 2020, to facilitate the country’s response to the pandemic. One of the consequences of these periods was the relaxation of various health insurance and employee benefits-related rules, timelines, and deadlines. Employers must now prepare for the reinstatement of the previously modified guidance during the national state of emergency.

Under the Public Health Emergency (PHE), group health plans must cover the expenses of COVID-19 tests and testing-related services without cost-sharing, prior authorization, or other medical management requirements. This mandate was extended to cover over-the-counter home COVID-19 test kits. While the PHE was initially set to expire on April 11, the government has extended the period until May 11, which is before the end of the original 90-day period. As a result, employer plans will no longer be obligated to cover such tests and services without cost-sharing.

A number of employee benefit plan-related deadlines were put on hold for up to one year while the national emergency was in effect. However, with the national emergency declaration ending on May 11th, the 60-day countdown after the termination of the national emergency will commence on May 12th.

Once this 60-day period ends, these suspended timeframes will begin to run again at pre-pandemic rates effective July 11 and include:

• the 14-day deadline for plan administrators to provide COBRA-election notices to qualified beneficiaries.

   

• the 30-day period (or 60-day period, in some cases) co exercise HIPAA special enrollment rights in a group health plan following birth,  adoption  or  placement  for  adoption of a child; marriage, loss of other health coverage, or eligibility for a state premium assistance subsidy.
• the 60-day deadline by which a participant or qualified beneficiary must provide notice of divorce or legal separation, a dependent child that ceases to be an eligible dependent under the terms of the plan) or a Social Security disability determination used to extend COBRA coverage.
• the 60-day deadline in which to elect COBRA coverage.
• the 45-day grace period for the payment of initial COBRA premium, and 30-day period for subsequent premium payments. Note: Presently, individuals electing COBRA outside of the initial 60-day election period (as referenced above) generally have one year and 105 days after the election notice is provided to make the initial premium payment, and individuals electing COBRA within the generally applicable 60-day election period nave one year and 45 days after the date of their election to make the initial payment.
• the deadline under the plan by which providers and participants may file a benefit claim (generally one year, under the terms of the plan).
• the deadlines for appealing an adverse benefit determination (generally 30 days), requesting an internal review (generally six months) or an external review of a claim denial (generally four months).

The end of the public health/national emergency on May 11th will not affect the guidance that allows HSA-qualified high deductible plans to offer first-dollar telehealth coverage without impacting HSA eligibility. This relaxation remains in effect through 2024, as stated in the Consolidated Appropriations Act.

While offering biosimilars can be a great opportunity for employers, they need to consider important factors that drive market share when selecting a PBM and a biosimilar strategy. The pricing strategy should take into account list prices, discounts, financial assistance, and rebates to ensure the lowest net cost for both the plan sponsor and the patient.

It is important to understand that choosing the right biosimilar is crucial to maintain the balance in benefits between plan sponsors and employees. The success of biosimilars also heavily depends on prescribers feeling confident in their safety and efficacy.

Employers may find it overwhelming to navigate modern healthcare solutions, but brokers are accessible and ready to provide information about options such as biosimilars. It can be a smart choice for organizations that meet their needs and prioritize the well-being of their employees.

The end of the public health emergency will undoubtedly have a significant impact on the health insurance industry, as individuals and businesses adjust to the new normal. Hilgerman Insurance Solutions recognizes the importance of adapting to these changes and continuing to provide valuable health insurance options to our clients. As we move forward, it’s important to stay informed and remain vigilant in our efforts to maintain good health and protect ourselves and our loved ones. With the support of a trusted insurance provider like Hilgerman Insurance Solutions, individuals and businesses can feel confident in their ability to navigate these uncertain times.

Hilgerman Insurance Solutions
(805) 279-5482
deb@hilgermanins.com  
www.hilgermanins.com