Addressing common questions and concerns from clients and employees impacted by the coronavirus.
Group Management Services Inc., a Certified Professional Employer Organization based in Richfield, Ohio, assures clients access to the same level of support and resources throughout the Coronavirus pandemic.
"Our number one priority is getting employees paid and maintaining benefits for those employees," GMS President Mike Kahoe said. "As such, we are offering our customers grace period on all benefits, state unemployment, and workers' comp billings."
GMS wants to address all concerns, starting with the list of common questions we anticipate from our clients and employees.
Q: How will GMS employees be able to continue to work to ensure that my employees get paid during this crisis?
A: GMS has taken the precaution of instituting a company-wide work-from-home policy. In fact, a large percentage of our company already works from remote locations several days per week. This gives us a great deal of confidence in our ability to support you without disruption. Additionally, all GMS employees have access to all GMS systems, including phones and video conferencing, from wherever they work, and these systems are built on highly redundant platforms.
Q: How is GMS protecting my data during this crisis? Aren't allowances being made that could reduce the cyber protections in place to allow your employees to work from home?
A: GMS has invested in cyber security improvements over the last 18 months that are effective at protecting our Clients' data regardless of where you, or our staff, interact with it. All these safeguards remain in place, and we will maintain a high level of vigilance to ensure that your data and your employees' payroll is secure.
Q: Will my GMS plan pay for the COVID-19 testing (Codes U0001 and U0002)?
A: Yes. GMS will waive member cost share for these tests when administered by in-network providers in accordance with the CDC guidelines.
Q: Will my GMS plan cover the treatment for COVID-19?
A: Yes. Treatment for COVID-19 is eligible under the normal provisions of the plan when following CDC guidelines.
Q: If I lay off part of my workforce in response to the COVID-19 crisis, can the company continue to cover those employees?
A: Yes. As long as you continue to pay premiums, you may continue to cover laid-off employees even though they are not actively at work. Please note that you must administer the plan on a uniform, non-discriminatory basis. In other words, you may not choose to pay premiums for only certain people.
Q: If I have to lay off my entire workforce in response to the COVID-19 crisis, can the company continue to cover those employees?
A: Yes, as long as one person remains actively employed by the group. If you continue to pay premiums, you may continue to cover laid-off employees even though they are not actively at work. Again, this must be administered on a uniform, non-discriminatory basis.
Q: What about continuation of coverage?
A: As long as one person remains actively employed, employees may be offered COBRA and may elect to continue coverage under COBRA under the normal notice and election procedure.
* If the plan has no active employees, the plan is terminated and COBRA is not an option. In that case, employees would have a special enrollment period to enroll in individual coverage or could purchase a short-term plan that is subject to medical underwriting.
Q: If I have to terminate coverage for my employees in the middle of a month, will I receive a refund of my premium for the rest of the month?
A: While your contract states that GMS will not refund a partial month's premium, we will refund the proportional amount of premium should you terminate your coverage before the end of the month given the gravity of the current situation.
Q: In light of the COVID-19 crisis, can I get a grace period extension on paying my premium?
A: Yes. GMS is offering to extend the grace period for your next monthly premium payment by up to 60 days.
Q: Will employees who are laid off temporarily as a result of COVID-19 concerns be permitted to rejoin the plan without a waiting period when they return to work?
A: Yes. There will be no waiting period for current employees who are rehired by May 31, 2020. New hires are subject to any waiting period the plan requires.
Q: Will I lose my job-based group-health coverage?
A: You may qualify for tax credits that can lower your monthly premiums and for lower out-of-pocket costs. Please inquire with your Benefit Account Manager if you have any questions.
Q: Is our GMS pharmacy plan through MedTrakRx going to allow early re-fills on prescriptions if necessary?
A: MedTrak has relaxed its refill-too-soon edits for non-opioid and non-specialty medications. These are not changes that will happen automatically and will occur at the discretion of dispensing pharmacists.
Q: What does the Families First Coronavirus Response Act mean to covering testing for Covid-19?
A: On March 18, 2020, President Trump signed the second coronavirus relief measure into law – the Families First Coronavirus Response Act (Act). Effective immediately, the Act requires group health plans and health insurance issuers to cover COVID-19 testing without imposing any cost sharing (such as deductibles, copayments, or coinsurance) or prior authorization or other medical management requirements. During this public health emergency, health plans and issuers must cover FDA-approved diagnostic testing products for COVID-19, including any items or services provided during a visit to a provider (in-person or telehealth), urgent care center or emergency room that relate to COVID-19 testing. This coverage cannot be subject to any plan deductible, copayment, or coinsurance. This coverage mandate does NOT require health plans and issuers to cover COVID-19 treatment at no charge. Exact coverage details for COVID-19 treatment, including any cost-sharing amounts, will vary by plan.
Q: Will private health plans cover the cost of COVID-19 diagnostic testing that occurs prior to April 2?
A: Yes, this section of the legislation is effective from the date of enactment, March 18, 2020, through the end of the national emergency period. The Act states that “a group health plan and a health insurance issuer offering group or individual health insurance coverage shall provide coverage, and shall not impose any cost sharing (including deductibles, copayments, and coinsurance) requirements or prior authorization or other medical management requirements” for specific items related to testing or related health care provider visits.
Q: What should Employers do if an employee discloses they have been in close contact with a person who tested positive or who is awaiting test results for COVID-19?
A: According to the CDC, individuals who have had close contact with a person diagnosed with COVID-19 should self-quarantine. Employers can require an employee who has been exposed to the virus to stay home. Your HR Account Manager would be happy to help you navigate through these types of situations.
Q: If an Employer is considering a temporary or permanent lay off what steps should be considered?
A: Employers should work closely with their HR Account Manager who will help guide them through this process. Items to consider include how to appropriately select employees for lay off, necessary documentation to provide to the employee, COBRA and Health Care Benefits (if applicable), and assisting with unemployment benefits.
Q: If my state has instituted a “Stay at Home” order allowing only Essential Businesses to continue operation, what qualifies as an “Essential Business?”
A: In Ohio, for example, essential businesses are allowed to continue to operate, but must comply with social distancing requirements. A few examples of these are:
- Healthcare and public health operations
- Human services operations
- Essential infrastructure
- Essential government functions
- Stores that sell groceries and medicine
- Food and beverage production and agriculture
- Charitable and social services
- Gas stations and businesses needed for transportation
- Critical trades
- Restaurants for off-premise consumption
- Professional services
- Home-based care
For the full order and list, please reference the following link - Order to Stay at Home.
The Governor of Ohio has issued a Stay at Home Order effective March 23 at 11:59 p.m. and lasting for the next two weeks. Group Management Services is considered an Essential Business. All our services will continue as normal. We will also continue to monitor developments and recommendations from the CDC, Federal, State, and Local government. We hope you are doing well. Please let us know if there is anything we can do to help.
Q: What are my next steps?
A: If you are considered an essential business, we are happy to help guide you through the social distancing requirements. If you are unable to continue business because of the Stay at Home Order, we are happy to help you navigate next steps. If you have positions that have the ability to work from home, we are happy to help create a work from home policy. In the unfortunate event your business requires layoff of some or all of your workforce at this time, we can assist in documentation, communication, and next steps.
Q: President Trump signed the Families First Coronavirus Response Act (FFCRA) on March 18, 2020, so its provisions go into effect no later than April 2. Will the leave provisions, Emergency FMLA (EFMLA) and Emergency Paid Sick Leave (EPSL) be applied retroactively?
A: When a law is to be applied retroactively it will typically state so in plain language, which this legislation does not. Therefore, the law will likely not be enacted retroactively. GMS will alert you of any change to this.
Q: From now until April 2, how should we handle employees who need time away from work for COVID-19 related reasons? What documentation should we require?
A: Until the legislation takes full effect, continue handling these situations as you have been on a case by case basis. Work with your HR Account Manager for assistance. Rely on current employment policies, including but not limited to paid time off, paid vacation, sick leave, or other leaves of absence policies. Certification for certain absences (advisement by health care provider to self-quarantine, experiencing symptoms, seeking diagnosis) may be hard to obtain due to doctors not seeing patients, providing notes, or conducting full testing. GMS has created the attached Documentation on a COVID-19 Absence that may be used to gather facts and communicate details of a potential leave of absence. This would be filed in the employee’s confidential personnel file.
Q: Do you have the forms necessary for employees to file for EFMLA and EPSL?
A: No, official forms or documentation have not been released yet by the Federal government. We will provide if, and when, they become available.
Q: Do we have to offer EFMLA and EPSL to employees who are already or who will be laid off prior to April 2?
A: No, if employees are laid off, they become eligible for unemployment compensation under the Emergency Unemployment Insurance Stabilization and Access Act. This is handled separately from EFMLA and EPSL.
Q: If I cut an employee’s hours, can they apply for partial unemployment?
A: Yes, an employee experiencing a reduction in hours may apply for and obtain unemployment benefits. In Ohio, if the reduction in hours is due to COVID-19, employee should provide Mass Layoff ID# 2000180. These layoffs will not affect your unemployment rate as all coronavirus layoffs will be charged to the Ohio Unemployment Mutual Fund and will not be charged to your account.
Q: If an employee is CHOOSING to stay home out of fear of exposure, how do you recommend we handle this scenario?
A: Evaluate the safety precautions you, as a business, have taken to protect employees and prevent the potential spread of COVID-19. If you feel that you have taken all preventative measures within reason, review your current time off policies and available time off balances with the employee, or explain the unpaid model you have been utilizing.
Q: How can an employer apply for and receive the small business exemption to the leave provisions of the FFCRA?
A: Employers with fewer than 50 employees are eligible for an exemption from the requirements to provide leave in cases where the viability of the business is threatened. That said, it remains to be seen how to request an exemption and for which provisions of the legislation the exemption will apply to. Please note the FFCRA allows tax credits up to 100 percent of the cost of paid leaves. Under guidance that will be released this week, eligible employers who pay qualifying sick, childcare, or other leave will be able to retain an amount of the payroll taxes equal to the amount of qualifying leave paid, rather than deposit them with the IRS. Per the legislation and the IRS, the payroll taxes that are available for retention include withheld federal income taxes, and both the employee and employer share of Social Security and Medicare taxes.
We will be covering tax credits and small business relief on Friday, March 27, 2020 during the next webinar in our COVID-19 webinar series. Please join us. You may register here: https://attendee.gotowebinar.com/rt/6872645169703825931
Q: Will Coronavirus related layoffs affect my unemployment rate?
A: Every state is different. In Ohio (where we are headquartered), these layoffs will not affect your rate. All coronavirus layoffs will be charged to the Ohio Unemployment Mutual Fund and will not be charged to your account.
Q: Will my employees have a waiting week before their unemployment starts?
A: No, Governor DeWine (Ohio) has waived the waiting period for all lack of work claims so employees can start collecting as soon as the claim has been processed.
To learn more about GMS, visit https://www.groupmgmt.com/about-us/.