BlueChoice HealthPlan of South Carolina and BlueCross BlueShield of South Carolina COVID-19 Pandemic Group Eligibility Guidelines Extended Through December 31, 2020

Existing COVID-19 Federal Supply
COVID -19 vaccines obtained from the existing federal supply will remain free to members even after the end of the PHE. COVID-19 vaccines obtained from sources other than the federal supply will be covered per plan documents and as outlined below. The federal government is expected to provide updates on the federal supply status.

Non-Grandfathered Plans
Because the COVID-19 vaccine is recommended by the Advisory Committee on Immunization Practice (ACIP) and approved by the Centers for Disease Control and Prevention (CDC), Affordable Care Act rules regarding coverage under non-grandfathered plans apply as they do for all ACIP-recommended and CDC-approved vaccines. Therefore, after May 11, 2023, we will cover the COVID-19 vaccine and its administration without cost-sharing under non-grandfathered plans, as long as the vaccine is provided by in-network providers. When furnished by an out-of-network provider, the COVID-19 vaccine along with its administration costs will be processed the same as other vaccines under the terms of the plan and may be excluded from coverage or require cost sharing after May 11, 2023. As noted above, COVID-19 vaccines sourced from the federal supply will have no costs. Plan documents should be reviewed for exclusions or cost-sharing requirements prior to receiving any vaccine from an out-of-network provider. Out-of-network vaccine coverage may vary among non-grandfathered plans. 

Grandfathered Plans
For grandfathered plans, after May 11, 2023, the COVID-19 vaccine along with its administration costs will be processed the same as other vaccines under the terms of the plan and may be excluded from coverage or require cost sharing regardless of provider network status. As noted above, COVID-19 vaccines sourced from the federal supply will have no costs. Members should review their plan documents prior to receiving any vaccine. Vaccine coverage may vary among grandfathered plans.

Regular coverage and cost sharing will apply starting May 12, 2023, to the test and associated doctor visit according to plan benefits. 

Employer groups who offer HSA-eligible HDHPs may continue to cover testing for members who have not yet met their deductible, without jeopardizing their eligibility for an HSA, until further notice from the IRS. 

Regular coverage and cost sharing applies, as it did during the PHE, according to plan benefits. 

Pharmaceutical treatments (e.g., Paxlovid™) obtained from the federal government are not affected by the end of the PHE and will remain free, based on the federal supply. Treatment obtained from sources other than the federal supply will be covered according to the plan’s terms of coverage and subject to cost sharing requirements.

Employer groups who offer HSA-eligible HDHPs may continue to cover treatment for members who have not yet met their deductibles, without jeopardizing their eligibility for an HSA, until further notice from the IRS. 

HSA-eligible HDHPs may continue to offer telehealth to members who have not yet met their deductibles, without jeopardizing their eligibility for an HSA, until the end of plan years beginning in 2024 (i.e., until Dec. 31, 2024, for calendar year plans).

The exemption that allowed large employers to offer “stand-alone” telehealth plans that are exempt from many rules under the ACA will last until the end of the latest plan year that began during the PHE (until Dec. 1, 2023, for calendar-year plans). 

Emergency relief — which extended by up to one year certain deadlines that otherwise would have expired after July 10, 2022 — will end July 10, 2023. The normal, un-extended COBRA, HIPAA, and claims and appeals time-frames are scheduled to begin applying on July 10, 2023. Although the national emergency ending on April 10, 2023, could shorten the above date by one month, July 10, 2023, should remain as the emergency relief expiration date unless a different date is specifically listed in future government guidance.

Individual deadlines that will shift include:
•    Electing COBRA and making COBRA premium payments.
•    Submitting claims and appeals.
•    Requesting and providing information for external review.
•    Notifying the plan of a COBRA qualifying event or disability.
•    Requesting special enrollment. 

Examples of the timeline impacts are available in the following government FAQs:
https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/aca-part-58

The relief that allowed plans to provide certain documents “as soon as administratively possible” will also end.