ODA Wellness Trust response to COVID-19

Governor DeWine recently announced policies suspending or modifying business operations to help stem the spread of COVID-19. In light of this announcement, ODASC has been working with vendor partners to take proactive steps in providing as much flexibility as possible for those members and staff enrolled in the ODA Wellness Trust. To assist you, ODASC has prepared the following FAQ which addresses the ODA Wellness Trust’s response to COVID-19 and how dental offices can continue health coverage for their employees enrolled in the ODA Wellness Trust.

Q: How does my practice continue employee coverage as normal while the office is closed?

A: Continue remitting your monthly payments to ODA Wellness Trust as if your employees were actively working. You will need to arrange a method for your employees to remit their portion of health care fees directly to you since there will be no regular payrolls from which you may withhold health care fees. Please note, employer-subsidies towards health insurance premiums (and other forms of compensation) may be considered remuneration that reduces or denies the employee’s unemployment compensation. Please contact the Ohio Department of Job and Family Services if you or your employees have questions about unemployment compensation.

Q: If I lay off part of my workforce in response to the COVID-19 crisis, can my office continue to cover those employees enrolled in the ODA Wellness Trust?

A: Yes. You may continue offering benefits without placing the laid off employee(s) on COBRA or you may also choose to utilize COBRA benefits.

If you wish to continue offering benefits without placing the laid off employee(s) on COBRA, the intent must be to rehire these employees and you must administer the plan on a uniform, non-discriminatory basis. In other words, you may not choose only certain people for whom you continue to provide coverage. Finally, to ensure coverage is uninterrupted, it is important that you continue to pay your ODA Wellness Trust invoices as billed (see extended grace period question below).ODA Wellness Trust has established a period of 90 days from March 1, 2020, during which employees on unpaid leave may continue to be eligible for coverage. 90 days after March 1st, the expectation is that employees will be transitioned to federal continuation coverage under COBRA. ODA Wellness Trust understands that Ohio’s COVID-19 situation is changing daily and will continue to monitor and communicate any changes.

If you intend to continue offering benefits through the ODA Wellness Trust to your staff without placing laid off employees on COBRA, please promptly notify ODASC of your laid off employees by completing this COVID-19 Temporary Layoff Verification form and emailing it to insurance@oda.org or faxing it to 614-340-9444.

If you intend to forego this option and wish to utilize the COBRA benefits for laid off staff, please notify ODASC by sending an email to insurance@oda.org.

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 your intention is to rehire these employees, you can 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 only certain people for whom you continue to provide coverage. Finally, to ensure coverage is uninterrupted, it is important that you continue to pay your ODA Wellness Trust invoices as billed (see extended grace period question below). ODA Wellness Trust has established a period of 90 days from March 1, 2020, during which employees on unpaid leave may continue to be eligible for coverage. 90 days after March 1st, the expectation is that employees will be transitioned to federal continuation coverage under COBRA. ODA Wellness Trust understands that Ohio’s COVID-19 situation is changing daily and will continue to monitor and communicate any changes.

It is important to understand that under this scenario where a dentist’s entire workforce is laid off, at least one employee must remain on the ODA Wellness Trust to maintain the employer plan. This employee can be the dentist or one of the staff members.

If you intend to continue offering benefits through the ODA Wellness Trust to your staff, please promptly notify ODASC of your laid off employees by completing this COVID-19 Temporary Layoff Verification form and emailing it to insurance@oda.org or faxing it to 614-340-9444.

If you intend to forego this option and terminate your employer plan, please notify ODASC by sending an email to insurance@oda.org.

Q: What about continuation coverage for the ODA Wellness Trust?

A: All employers enrolled in the ODA Wellness Trust are subject to COBRA. Under normal circumstances, if an employee’s hours are reduced (for example, by a layoff), they would be allowed to elect continuation coverage under COBRA. However, if all employees enrolled in their employer plan are laid off and the employer has no active employees, the employer plan is terminated and COBRA is not an option. In this case, employees would have a special enrollment period to enroll in individual coverage or purchase a short-term plan that is subject to medical underwriting.

Given the circumstances and a large amount of workers expected to be temporarily laid off, a waiver has been received for minimum enrolled of active employees in the plan. Therefore, if all employees enrolled in their employer’s plan (as part of the ODA Wellness Trust) are laid off, their employer plan will continue to cover them during the lay off period and then once they return to work, coverage will continue as if there were no gap in employment. It is important that this coverage only apply to those employees which you intend to rehire.

Q: Is there an extended grace period for paying my ODA Wellness Trust invoice during the COVID-19 outbreak?

A: Given the financial burden placed on dental practices during this unprecedented time, the ODA Wellness Trust is offering to extend the grace period for your next monthly payment by 30 days. With this extension, delinquency notices will be suspended and your coverage will not be interrupted.

Q: How is COVID-19 Coronavirus testing covered by the ODA Wellness Trust?

A. To help combat the spread of COVID-19, the ODA Wellness Trust is covering all diagnostic testing for the virus, as long as it is ordered by a medical provider. We are also waiving all member cost sharing, including copays, coinsurance and deductibles for these tests.

Q: What if I (or my employees) am enrolled in a High Deductible Health Plan? Is the COVID-19 Coronavirus testing still available at no member cost sharing?

A. Yes. The IRS issued guidance on March 11, 2020, allowing pre-deductible coverage of testing for COVID-19, as determined by the health plan. This applies to high-deductible health plans (HDHP) with health savings accounts (HSA). This means that ODA Wellness Trust’s HDHPs with HSAs can cover COVID-19 testing without member cost sharing.

Resources

ODASC will continue to monitor and follow all guidelines issued by the Centers for Disease Control and Prevention (CDC), Centers for Medicare & Medicaid Services (CMS), the US Food and Drug Administration (FDA), the Ohio Department of Health (ODH) and other state and local public health departments in supporting our members' needs. We encourage our participants to seek information from the following sources:

· ODA: https://oda.org/member-resources/covid-19/

· CDC: https://www.cdc.gov/coronavirus/2019-ncov/index.html

· ODH: https://odh.ohio.gov/wps/portal/gov/odh/know-our-programs/Novel-Coronavirus/2019-nCoV

· Medical Mutual: MedMutual.com/Coronavirus.

The ODA Wellness Trust does not provide employers or participants with legal advice. You may wish to consult with your attorney before agreeing to offer temporary COVID-19 layoff continuation coverage to employees. If you have questions about the ODA Wellness Trust’s response to COVID-19, please don’t hesitate to contact ODASC at 1-800-282-1526 or insurance@oda.org.