By Ashley Snodgrass, Employee Benefits Analyst
The end of COVID has been up for debate. Some people feel as though the pandemic was over when the mask mandates went away, while others think the pandemic ended as soon as vaccines were available. And then there are some super rosy people who say the pandemic will never be over! What is the truth?
One way to look at the end of COVID-19 is to recall the start of the pandemic. On January 31, 2020, Secretary of Health and Human Services, Alex Azar, declared a public health emergency due to confirmed cases in the United States of the 2019 Novel Coronavirus. This official order stated the public health emergency has existed since January 27, 2020. After a long and interesting three years, the Biden Administration is ready to end the public health emergency on May 11, 2023. Even though life has resumed some semblance of a “new normal” for many people, the end of this public health emergency will still have some meaningful impacts for health plans.
For example, health plans will no longer have to cover COVID-19 testing with no member cost sharing. Also, health plans will only be required to cover in-network COVID-19 vaccines, similar to other preventive services requirements. Health plans that offer COBRA coverage must ensure that regular deadlines resume too – such as the 60-day election period for COBRA.
I would recommend that you review this handy document from Zywave for a detailed account of all the changes that will be triggered by the end of the public health emergency. Don’t let these end-of-pandemic changes catch you as off guard as the start of the pandemic.
For questions about what this could mean for your organization, please contact your RISQ Employee Benefits Consultants or Account Executive, or email@example.com.
This article is from RISQ Consulting’s Zywave client portal, a resource available to all RISQ Consulting clients. Please contact your Benefits Consultant or Account Executive for more information or for help setting up your own login.
If you participate in a health plan—through your employer or otherwise—you are likely eligible for free, over-the-counter COVID-19 tests for home use. Depending on your plan, your COVID-19 tests will be paid for directly by insurance, or you will be reimbursed later for the cost. The human resources (HR) department will be able to tell you which applies to you. Keep reading to learn more about this cost-saving opportunity.
Up to what price is covered?
In many instances, insurance companies are only required to reimburse you at a rate of up to $12 per individual test (or the cost of the test if it’s less than $12). This is typically the case when your insurance company has specific locations they want you to get your test from. However, if your insurance company doesn’t specify where you may get a COVID-19 test, you may be able to be reimbursed for your full test cost, even if it exceeds $12. In all cases, keep your receipts! Speak with your HR department to learn more about your plan’s cost limits and preferred purchasing locations.
Do I need to purchase the test at a certain location for it to be free?
Your employer may have specific locations (e.g., pharmacies) where you can pick up a free test that is paid for directly by your insurance. Your HR department will be able to tell you. However, you can also purchase a COVID-19 test from anywhere you like (i.e., online or in-person at a store) and still be reimbursed up to $12 for the test (or more, depending on your plan). Be sure to keep your receipts in order to be reimbursed.
How will I be reimbursed for my test?
If you need to be reimbursed for a COVID-19 test (i.e., it was not free at the point of sale), keep your receipts. Then, reach out to your HR department —they will be able to tell you how to submit the receipt for reimbursement from your insurance company.
How long will reimbursement take?
Reimbursement is typically prompt, but it may vary. Your HR department will be able to provide a more accurate time estimate.
What if I cannot afford to pay for a test upfront and wait for reimbursement?
There are a number of low- or no-cost COVID-19 testing options. You can find community-based testing sites here. Alternatively, COVID-19 tests are also available without cost sharing or limitations to covered individuals when administered by a health care provider (e.g., a nurse, doctor or pharmacist).
Can I be reimbursed for past COVID-19 tests I purchased?
Insurance companies are only obligated to reimburse you for COVID-19 tests purchased on or after Jan. 15, 2022. Any tests bought before then are not covered. However, while the answer will generally be no, you still can speak with your plan sponsor about potential reimbursement for COVID-19 tests you bought previously.
Is there a limit on the number of tests I can be reimbursed for?
Your plan is required to provide reimbursement for eight tests per month, regardless of whether the tests are bought all at once or at separate times throughout the month.
My workplace requires weekly COVID-19 testing. Can I be reimbursed for these tests?
Plans are not required to provide coverage for testing (including at-home COVID-19 tests) that is for employment purposes. Speak with your HR department to learn more about ’s testing requirements and your potential related costs.
Where can I learn more?
If you have any questions about the information in this article, reach out to your HR department.
Announcement by the RISQ Consulting Team
On November 16, 2021, OSHA published an announcement stating that they are unable to implement or enforce the vaccine and testing mandates for private employers that were set to begin in early December and early January.
The US Court of Appeals for the Fifth Circuit ordered that OSHA pause the implementation and enforcement of the Emergency Temporary Standards (ETS) until future court order, due to pending litigation. Several legal issues have been raised in response to OSHA’s ETS that required private employers with more than 100 employees to require employees to receive COVID-19 vaccines or be tested weekly for COVID-19.
The US Court of Appeals for the Sixth Circuit was selected through a lottery process to review the ETS arguments, which is the next step.
At this point, employers should continue to monitor the OSHA ETS updates for any status changes. Employers are encouraged to understand the requirements of the ETS, should the case last through the legal challenges and quick implementation be required.
Special Note for Federal Contractors and Healthcare Entities: The suspension of the implementation and enforcement of the vaccine mandate is specific to OSHA’s mandate for private employers with more than 100 employees. The vaccine requirement for Federal Contractors is not affected by the block of the ETS. The vaccine requirement from CMS for staff at health care facilities that participate in Medicare and Medicaid programs is not affected by the block of the ETS.
Links to Additional Reading:
SHRM: 6th Circuit to Review OSHA’s Workplace Vaccine-or-Testing Rule
SHRM: Federal Contractor Employees Must Be ‘Fully Vaccinated’ by Jan. 18, 2022
National Law Review: What Healthcare Employers Need to Know About the Centers for Medicare & Medicaid Vaccine Mandate
National Law Review: Fate of OSHA’s COVID-19 Vaccine ETS in the Hands of Sixth Circuit Court
RISQ Consulting will continue to monitor the situation and legal challenges, sending updates as new relevant information becomes available.
Click HERE to view the News Brief.
If you have any questions about how the OSHA ETS may apply to your company, or any other questions about COVID-19, please contact your RISQ Consulting Account Executive or Account Manager.