To provide relief for people affected by the COVID-19 pandemic, the federal government issued a rule and related guidance giving employees and non-Medicare retirees flexibility to make changes to their group health plan coverage and more time to complete certain transactions. Eligible individuals may request changes starting June 1.
Changes allowed due to COVID-19
Until Oct. 28, 2020 (just before open enrollment), employees and non-Medicare retirees will have the option to:
- Enroll in new medical coverage
- Change plans or coverage level (e.g., self to family)
- Cancel coverage — For plans other than CORE the participant must submit Form UBEN 230 attesting that they have other coverage
For any of these changes, your coverage choice is effective the first of the month following the date you submit your request. There is no 90-day waiting period for coverage to begin. If you’re moving to a new plan, your deductible (if any) and out-of-pocket maximum will reset to $0 when your new coverage begins; expenses paid through your previous plan will not carry over.
UC Health savings plan
The exclusion of COVID-19 testing and telehealth services from the deductible and cost-sharing is retroactive to Jan. 1.
Health and dependent care flexible spending accounts (FSAs)
Until Oct. 28 (just before open enrollment) employees will have the option to:
- Cancel your 2020 participation
- Enroll for 2020
- Change your 2020 election
Changes go into effect the first of the month after the request is made, taking payroll deadlines into account (See “How to request a change,” below). You’re only able to change your coverage choices moving forward. In other words, any changes you make will be prospective, not retroactive.
If you disenroll from your FSA, you may only be reimbursed for expenses from Jan. 1 (or your start date) through the date you stop participating – unless you enroll again promptly once your situation returns to normal. To continue to use funds remaining in your account without making additional contributions, you can reduce your contribution to the amount you’ve contributed year-to-date.
IRS rules do not allow refunds of FSA contributions that have already been made in 2020. WageWorks will deny your request if your new election amount is less than your year-to-date contribution, or if it is less than the amount already reimbursed this year under the Health FSA.
UC has been authorized to increase the amount that can be carried over from 2020 to 2021 from $500 to $550.
More time to file claims, file appeals and apply or pay for COBRA
Due to the extreme disruptions caused by the COVID-19 pandemic, the federal government has extended the time allowed for employees and non-Medicare retirees in group health plans to take certain actions — including submitting claims, electing and paying for COBRA continuation coverage, enrolling in group health plan coverage under HIPAA special enrollment rights, and filing appeals for adverse benefit determinations.
If a qualifying event occurs between March 1, and the end date of the current National Emergency (which has not yet been determined), the amount of time allowed for participants to take action allowed by the qualifying event does not begin until 60 days after the date the National Emergency is officially determined to have ended.
For UC, this change applies to the following plans:
- Medical (excluding UC Medicare plans)
- Basic & Voluntary Disability (for filing claims, but not for enrollment)
- Life and AD&D (for filing claims, but not for enrollment)
- Health Flexible Spending Account
Please note that the DepCare FSA, Supplemental Health Plans and Legal Plan are not included in these changes.
The amount of time a participant has to enroll in a health plan (medical, dental, vision and Health FSA) will be extended for certain types of life events, including addition of a spouse, domestic partner or child, loss of other coverage (including Medicaid or CHIP), or becoming eligible for a Medicaid/CHIP premium subsidy. Note that the plan enrollment extension does not apply to disability or life insurance.
For example, if a family member became eligible for coverage on or after March 1, you now have additional time to enroll your family member (even if your regular enrollment deadline has passed). You also have additional time to file claims for medical, dental or vision services.
Health FSA participants have additional time to request reimbursement for expenses incurred in 2019, using the remaining balance from last year (the original April 15 deadline does not apply this year). In addition, during the extended deadline, debit cards will not be suspended because WageWorks has not received substantiating documents. Any debit cards suspended since March 1 will be reactivated.
How to request a change
Eligible individuals may begin requesting changes as of June 1, 2020. You may not make multiple elections during the election period provided through these new rules. (For example, you may not cancel your participation in an FSA and then re-enroll.) You may submit an appeal if you need an exception due to extenuating circumstances.
For employees on UCPath, including employees at UCSF and UC San Diego, please sign into your UCPath account, select “Ask UCPath,” and submit an inquiry to request that an event be opened. From the inquiry page, select:
- “Topic” = Benefits
- “Category” = Benefits Election Inquiry
- “Type Subject” = Request COVID-19 Event
- In “Type Description,” please provide yes/no answers to the following questions, numbering your answers for easy reference:
- Did you add a family member, through marriage, establishment of a domestic partnership, birth, adoption, or placement for adoption?
- Did you lose medical coverage (for example, loss of coverage through your spouse/domestic partner or parent, moved out of the HMO service area, or became ineligible for Medicaid/CHIP)?
- Did you become eligible for Medicaid or the CHIP Premium Assistance Program?
Once the event has been opened, you will have 31 days to log into the UCPath portal and make your desired changes. The event will close automatically after 31 days if no action is taken. You may need to complete Form UBEN 230 to cancel your medical coverage.
Changes made in response to a life event such as marriage, birth of a child or loss of coverage are retroactive to the date of the event, and you will be responsible for any retroactive premium. For all other changes to elections, the effective date will be the first of the month following the date the event was opened in UCPath, not the date you make a change. For example, if the event opens in UCPath on June 15 and you make changes on June 16, the changes will go into effect prospectively on July 1. If you do not make a change until July 5, the changes will go into effect retroactively on July 1. The date of the changes is subject to payroll deadlines.
For Lawrence Berkeley National Lab, employees must submit a UPAY850 form to request changes. The UPAY850 form may be signed and submitted online using Hello Sign. For non-Medicare retirees, a UPAY100 form must be submitted to the Retirement Administration Service Center (RASC). Changes will go into effect prospectively on the first of the month following the submission of the form.