Montgomery County Public Schools

New Benefit Guidelines Released Due to COVID-19 for Plan Participants and Beneficiaries Affected by the Pandemic

The Department of Labor and the Internal Revenue Service released new guidelines to benefit plans due to the COVID-19 pandemic.

MCPS-provided medical insurance plans are eliminating financial barriers for members to ensure that retirees and their family members covered by an MCPS health insurance plan receive the medically necessary services to detect and treat COVID-19.

• CareFirst will waive copays and out-of-pocket expenses—for out-of-network visits—for testing, diagnosis, and treatment of COVID-19. (Out-of-network providers can balance bill amounts over allowable charges.) CareFirst will maintain these provisions until the COVID-19 national emergency ends.
• Kaiser Permanente of the Mid-Atlantic States will waive cost sharing for testing, diagnosis, and treatment of COVID-19 through December 31, 2020.

Changes to health benefit plans

As a result of the new guidelines—

1. Any retiree who was eligible for health insurance benefits at the time of retirement who did not enroll during the Benefits Open Enrollment in October 2019, will be eligible to enroll in an MCPS health insurance plan. Retirees can also enroll their dependent(s) who were eligible to be enrolled at the time of the retirement by providing appropriate supporting documentation.

2. Any retiree who wishes to drop an existing dependent may do so by providing supporting documentation to show that the individual has coverage elsewhere or by providing an affidavit.

3. Retirees also are able to change their plan elections, (e.g., changing from the CareFirst Point-of-Service plan to the CareFirst HMO plan, or from the Kaiser Permanente HMO plan to a CareFirst plan). They can also add qualifying dependents to their existing health insurance or drop them from the plan, thereby changing the coverage level.

4. Retirees may add or drop parts of their health insurance plan. For example, a retiree who currently is enrolled in a dental or vision insurance plan only can enroll in a medical and prescription plan.

MCPS retirees must submit a completed MCPS Form 455-22, Retiree Benefit Plan Enrollment to enroll in or change their health insurance plan elections.

Changes to claim and other deadlines

The following claim-related deadlines are extended to exclude from the deadline period days from March 1, 2020 until 60 days after the end of the national emergency.

• Filing a claim
• Filing an appeal of an adverse benefit determination (180 for group medical; 60 days for other ERISA benefits)
• Filing a request for external review

In addition, the following COBRA plan provisions also are similarly extended.

• 30-day deadline for employers to notify the plan administrator of the occurrence of a COBRA-qualifying event (e.g., retiree divorce, dependent age-off). MCPS will continue to make every effort to report the COBRA-qualifying event within the 30 days to Benefit Strategies, the MCPS COBRA plan administrator.
• 14-day deadline for plan administrator (Benefit Strategies) to provide a COBRA election notice in the event of a COBRA-qualifying event. Benefit Strategies will continue to make every effort to provide the COBRA notices to eligible individuals.
• 60-day deadline for qualified beneficiaries (former employees) to notify the plan administrator (Benefit Strategies) of the occurrence of a COBRA-qualifying event (e.g., divorce).
• 60-day deadline to notify the plan of a determination of disability.
• 60-day deadline for former MCPS employees or aged-off dependents to elect COBRA coverage.
• 45-day deadline to pay the first premium and 30-day deadline to pay subsequent premiums.

Caremark/CVS Updates

Caremark/CVS Health is taking steps to care for our plan members and to help them adhere to their medications.

Relaxing Refill Restrictions

Caremark is waiving early refill limits on 30-day prescriptions for maintenance medications at any in-network pharmacy. Relaxing refill-too-soon limitations allows members to obtain maintenance medication prescriptions ahead of their normal fill schedule. This applies to all retiree prescription plans. The 30-day early fill override is a temporary process in effect for the current COVID-19 emergency situation. 

Members to Refill Maintenance Medications

We know that access to needed medication is important to you and your family members during the uncertainty caused by COVID-19. We strongly recommend you take action now for individuals who have long-term maintenance medications to refill eligible maintenance prescriptions for 90-day supplies.  

MCPS has a 90-day prescription benefit for maintenance medications at CVS pharmacy and the option of home delivery from CVS Caremark mail service pharmacy with no delivery cost.  

Free Home Delivery from CVS Pharmacy

Beginning immediately, CVS pharmacy will waive charges for home delivery of all prescription medications. With the Centers for Disease Control and Prevention encouraging people at higher risk for COVID-19 complications to stay at home as much as possible, this is a convenient option to avoid coming to the pharmacy for refills or new maintenance prescriptions.

Subsidy Available to Certain COBRA Participants 

The American Rescue Plan Act of 2021 (ARPA) provides for a 100 percent subsidy of COBRA premiums from April 1, 2021 to September 30, 2021 for Assistance Eligible Individuals (AEIs). To qualify, AEIs must have experienced a COBRA qualifying event other than a voluntary termination of employment. The subsidy is not available to people who voluntarily left their jobs.

Please note the following:

• Premiums for medical, prescription, dental, and vision coverage for all AEIs are subsidized at 100 percent during the coverage period.
• To qualify as an AEI, a person must be COBRA-eligible as of April 1 or later and not be eligible for other coverage during the subsidy period.
• The subsidy period lasts for up to six months (through September 2021) except for AEIs who exhaust their COBRA eligibility or qualify for other coverage. AEIs receiving the subsidy are required to inform the plan if they are eligible for other coverage.
• AEIs who become COBRA-eligible after April 1, 2021, receive the subsidy through September 2021, even if they receive less than six months of premium subsidies.
• The law establishes an extended election period of 60 days from receipt of the ARPA eligibility notice during which AEIs can enroll in subsidized coverage retroactive to April 1.
• AEIs are limited to switching to a plan with the same or lower premium plan than they had prior to the qualifying event.
• Employers are responsible for subsidizing the full premium plus the 2 percent administration fee. Companies will be reimbursed by credits against payroll taxes owed.

For further information, contact Benefit Strategies by telephone at 888-401-3539 or ERSC at 301-517-8100 or email ERSC.