Important COVID-19 Update

To Our Valued Clients and Partners

Today marks a full month that we have been reaching out to you about COVID-19. The past month brought unprecedented changes to our daily lives, our businesses, our communities, our nation, and our humanity as global citizens facing this pandemic together. We want to take this moment and express our deep appreciation for your partnership as we face the future together.
We realize that the amount of information and change coming at you and your members over the last few weeks can feel overwhelming. We hope that our weekly COVID-19 communications provide you valuable updates on how any changes affect your health plan or may affect your members. Today we are going to cover the topics that we’ve received the most questions about:

  • How does the CARES Act affect my health plan?
  • An overview of the recent changes to Telemedicine and Telehealth
  • Trends we are seeing and how they may affect your health plan
How does the CARES Act affect my health plan?
Bottom-line-on-top, the CARES Act does not require you to make any additional plan changes. However, some provisions within the Act may increase your plan costs. With regards to your health plan the CARES Act, does have impacts to how claims will be reimbursed. Out-of-Network care must be reimbursed at the rate posted on the provider’s website. We are continuing to seek clarification on Congressional intent as we prepare to implement the CARES Act requirements. There are some plan design opportunities embedded within the CARES Act, which includes allowing all telemedicine coverage to be covered before the deductible is met under a QHDHP paired with Health Savings Accounts, as well as feminine hygiene products are now considered qualified medical expenses for HSA and FSA reimbursement.

The Families First Coronavirus Response Act, signed on March 18 th by the 116 th US Congress, includes provisions for coverage of COVID-19 diagnostic testing. Our current Benefit Change Request Form addresses the Family First CR Act requirements. 

The CARES Act, signed on March 27th by the 116th US Congress, provides relief for small businesses impacted by the coronavirus pandemic is coming. Congress approved the CARES Act, a $2 trillion economic stimulus bill and the largest emergency aid package in U.S. history, to help affected Americans and businesses. 

The Keeping American Workers Paid and Employed Act , a subsection of the CARES Act, details provisions related to small businesses. Highlights include:

Loan assistance: Businesses with fewer than 500 employees (including sole proprietors, independent contractors and anyone otherwise self-employed) can apply for loans to meet payroll and cover certain other expenses like rent, utilities, and health insurance premiums.
  • If employers maintain their payroll, borrowers can apply for loan forgiveness.
  • Retroactive to February 15, 2020 to help bring workers who may have already been laid off back onto payrolls.
  • The new loans will be available through private financial institutions — i.e., banks, credit unions — that participate in the Small Business Administration’s lending network.
  • Please contact your Broker or Account Manager to discuss your plan’s member eligibility options with regards to leave of absences and attendance policies. 

Tax relief for wages and benefits: The new law provides a tax credit for retaining employees, worth up to 50% of wages paid during the crisis, for businesses forced to suspend operations or that have seen gross receipts fall by 50% from the previous year.
  • Check with the IRS or your accountant or financial advisor for more information and details regarding eligibility.
  • Please contact your Account Manager if you need assistance in obtaining historical enrollment or census information to support your application for tax credits. 

Interactions in programs available under the legislations:
There are restrictions around what programs can be utilized in combination with each other. For example, an employer can receive both tax credits for the qualified leave wages under the FFCRA and the Employee Retention Credit Under the Cares Act, but not for the same wages. The IRS has clarified that an Eligible employer may not receive the Employee Retention Credit if they receive a Small Business Interruption Loan under the Paycheck Protection Program that is authorized under the CARES Act ( “Paycheck Protection Loan”). An Eligible Employer that receives a paycheck protection loan should not claim Employee Retention Credits. The rules and nuances around what wages and costs can be included do differ, so please carefully review to determine which program(s) are the best suited for your individual circumstances, and consult with your tax and legal advisors to help you navigate the forms and tax filing requirements.

More information
An overview of the many recent changes to Telemedicine and Telehealth
What’s what?
Internally at RGA, we differentiate between the words ‘Telehealth’ and ‘Telemedicine’. However, outside of RGA the words ‘Telehealth’ and ‘Telemedicine’ are used interchangeably and can encompass a much broader scope of virtual healthcare services than how we define these words at our company.
This is how we define Telehealth and Telemedicine:
Telemedicine (updated definition for 2021 plan year and new amendments this year): covers medically necessary healthcare services between you and your physician to consult, treat, and prescribe for medical conditions. This benefit includes audio and video communication services, such as video conferencing and scheduled telephone visits. Telemedicine visits must be initiated at the request of you or your authorized provider, and replace the need for an in-person office visit. Scheduling and record-keeping standards that apply to in-person visits also apply to telemedicine visits.
Telehealth refers specifically to our buy-up MDLIVE partner product that many of our clients offer as a benefit for their members. Clients that choose MDLIVE as an added benefit decide the types of services (medical only, medical plus behavioral health, medical plus dermatology, or medical plus behavioral health, and dermatology).

What has changed?

COVID-19 is forcing dramatic changes in Telemedicine and Telehealth access and delivery.
1.       Many non-essential medical providers have closed their offices during shelter-in-place orders or cancelled appointments for non-acute services.
2.       People still need access to quality medical care without exposing themselves to extra germs by walking into a doctor’s office. Health officials warn people to stay away from medical facilities unless they need emergency care.
3.      A wave of regulatory changes emerge making way for seismic shifts in telemedicine and telehealth:
  • On March 17th the Trump Administration and the Department of Health and Human Services (HHS) announced unprecedented steps to expand Americans' access to telehealth services during the COVID-19 outbreak. The Centers for Medicare & and Medicaid Services (CMS) expanded Medicare coverage for telehealth visits, the HHS Office for Civil Rights (OCR) announced it will waive potential HIPAA penalties for good faith use of telehealth during the emergency, and the HHS Office of Inspector General (OIG) provided flexibility for healthcare providers to reduce or waive beneficiary cost-sharing for telehealth visits paid by federal healthcare programs.
  • On March 25th the Oregon Dept of Consumer and Business Services announced telehealth expectations for insurance plans.
  • On March 26th Gov. Inslee signed a proclamation on telehealth that provides payment parity between health care services provided in-person and those provided through telemedicine.
  • On March 27th the 116th US Congress passed the CARES Act which, among other things, provides safe harbor for waiver of telehealth and telemedicine deductibles for high deductible health plans. The CARES Act is an economic stimulus bill.
  • On March 30th the Federal Communications Commission (FCC) announced that it is launching a new telehealth program aimed at using $200M in new federal funding to improve broadband connectivity for connected health services.
  • During March 2020, 35 states and the District of Columbia opened their virtual borders by lifting their interstate licensure restrictions to allow doctors in any state to treat patients in their states. Currently, WA has not waived licensure, however, WA is part of the 29 state Interstate Medical Licensure Compact so some out-of-state providers may be eligible to practice in WA if they meet additional requirements.
4.       Thus, providers are quickly digesting these changes and standing up new telemedicine capabilities. 

How will my employees know if local community providers have telemedicine capability?
Members will need to call their providers to confirm if the provider has added this capability. Some providers may already serve members via telemedicine. Other providers are contacting their existing patients as telemedicine capabilities become available. Many community providers only offer telemedicine for their existing patients.

How are we accommodating plan changes for Telemedicine and Telehealth?
Some customers have already reached out to us to add telemedicine to their benefits so that members can access healthcare services without visiting a brick and mortar location. If you would like to add an option for telemedicine via community providers, we can make that change to your plan design immediately. This change option is available in the COVID-19 Benefit Change Request Form.

Add Telehealth through MDLIVE 
If you would like to add telehealth service via our MDLIVE telehealth product, we can also make that change. Please reach out to your Account Manager and we will send you a separate form to confirm your MDLIVE coverage preferences.

How long will it take to add MDLIVE
Adding MDLIVE services will likely take 10-15 days for MDLIVE to be set up for the first time. If you are simply making a change to your existing MDLIVE benefits, then the changes will only take a few days.
MDLIVE typically has a 60-day lead time for adding a new client. MDLIVE is working closely with us to add new clients on a much shorter lead time of approximately 10-15 days during this pandemic. During these rush additions we will need to receive information from you on a short turnaround time. We will provide you email templates that you can share with your members to invite them to register for MDLIVE or to inform them of upgrades to their MDLIVE coverage.
Can MDLIVE help members with COVID-19
MDLIVE providers can screen members for COVID-19. They cannot order COVID-19 lab tests. If you have a copay or deductible set up for non-COVID-19 related services with MDLIVE they cannot waive the copay or deductible upfront for COVID-19 related services. Members will have to pay their co-pay upfront and then we will mail them a reimbursement check after the claim is processed.

Can I add MDLIVE month-to-month?
Adding MDLIVE requires a minimum 90-day commitment post-implementation and at least a 30-day termination notice. MDLIVE services are available 24 hours per day and 365 days per year via phone, online via the myHMA portal or, or through the MDLIVE mobile app.
Each virtual consultation (visit) has a fee in addition to the PEPM. The fee schedule is based on the service provided. Current MDLIVE fee rates:  Medical: $38; Behavioral Health and Psychiatric Services: $85-$260; Dermatology: $60

MDLIVE wait times
Please be aware that wait times are longer than usual due to the high volume of calls MDLIVE & all telehealth vendors in the market are currently receiving. Members can choose to schedule an appointment at a later time or may need to wait 2-4 hours for an appointment. MDLIVE is actively working to increase capacity to support the surge in volumes. Please note, at this time, MDLIVE cannot order a COVID-19 diagnostic test.
Trends we are seeing and how they may affect your health plan
Over the last few days, we have seen a trend where fully-insured plans are announcing that they will go beyond federal and state regulatory requirements and cover 100% of costs related to COVID-19 treatment. At this time we recommend that you hold on making a similar decision. The costs of COVID-19 treatment are yet undetermined and as the steward of your plan dollars, we want to understand such costs first to help you make an informed decision. We know that acute COVID-19 treatment may require extended hospitalization including an ICU stay.
Within our membership, we saw a significant uptick in claim volume for COVID-19 testing on April 1 st. You can expect to see these claims begin to flow through your check runs in the next week.

We’re Here for You
As the number of positive COVID-19 cases grows, so does the likelihood that each of us will personally know someone that tests positive. Our focus, dedication, and support remain steadfast as we navigate these unique times with you. Thank you for your continued trust in our organization. We hope you and your loved ones remain safe and healthy. Please reach out to your Account Manager if you have any questions or if there’s anything we can do to help.

Best Regards,

Lindsay Harris
Chief Growth Officer
RGA - Proving What’s Possible in Healthcare ®