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Carriers Relax Requirements & Open COVID-19 Special Enrollment Periods

On March 21, 2020, The Wall Street Journal reported that, in response to the coronavirus, the Trump administration is considering opening a special enrollment period on, and now some carrier are following suit.

As COVID-19 continues to test our economy, many employers are being forced to make the difficult decision to lay off employees and institute furloughs or other temporary leaves of absence that cause employees to lose access to their employer-sponsored health coverage.

While the federal government ultimately decided against an Exchange special enrollment period, a number of states who operate their own Exchanges, including Colorado, Connecticut, Maryland, Massachusetts, Nevada, New York, Rhode Island, and Washington, have already announced COVID-19 related special enrollment periods. Importantly, these special enrollment periods only apply to state and federally sponsored Exchanges.

Employer-sponsored plans are subject to carrier approval and regulated by Section 125 rules that determine when employees can make mid-year election changes. While some carriers have announced special enrollment periods in response to COVID-19, originally the Section 125 rules were not revised to allow for cafeteria plan election changes because of COVID-19. Accordingly, any mid-year enrollments permitted from a carrier special enrollment period had to be provided on a post-tax basis outside of the employer’s cafeteria plan. However, on May 12, 2020, the IRS issued Notice 2020-29 and Notice 2020-33 to provide additional flexibility and clarification concerning cafeteria plans, health savings accounts (HSAs), health flexible spending accounts (FSAs), dependent care assistance programs or FSAs (DCAPs) and various flexible spending arrangements. One key change included new Section 125 mid-year election change options that will allow enrollment on a pre-tax basis.

Additionally, before implementing these relief efforts, employers should consider whether:

Here are some of the carrier relief plans that have been announced to date. For the most up-to-date information on additional carrier relief announcement, visit the carrier’s COVID-19 website.


  • $0 copays for COVID-19 related diagnostic testing and doctor visits.
  • Free home delivery on CVS Pharmacy prescriptions.
  • Waived all cost-sharing for any covered telemedicine visit (regardless of diagnosis) until June 4, 2020.
  • Waived early prescription refill limits on 30-day prescription maintenance medications.


  • Individuals with Anthem pharmacy benefits may refill a 30-day supply of most maintenance medications early.
  • COVID-19 testing is covered with no out-of-pocket costs and requires no preauthorization.
  • Effective March 19, 2020, for 90 days, cost sharing is waived for in-network telephonic visits and telehealth services through Anthem’s authorized telemedicine service, LiveHealth Online.

Blue Shield of California

  • Waived copays, deductibles, or coinsurance for testing to diagnose COVID-19 and related visits.
  • Lifted restrictions on early prescription refills.

BlueCross BlueShield (Various States)

  • Waived copays, deductibles, or coinsurance for testing to diagnose COVID-19 and related visits.
  • Lifted restrictions on early prescription refills.


  • Waived copays, coinsurance, and deductible during the public health emergency for COVID-19 testing and treatment.


  • Out-of-pocket costs for COVID-19 testing will be waived through May 31, 2020.


  • When recommended by a medical professional, Highmark will cover 100% of the cost of COVID-19 testing on most Medicare Advantage, ACA, and select employer plans.


  • No testing out-of-pocket costs for patients who meet CDC guidelines at approved COVID-19 laboratory locations.
  • Waived out-of-pocket costs for urgent care telemedicine visits for the next 90 days.
  • Early prescription refills allowed for the next 30 days.

Independence Blue Cross

  • Waived cost sharing for COVID-19 testing and primary care telemedicine visits through June 4, 2020.
  • Lifted “refill too soon” prescription restrictions.


  • Extended the 30-day grace period to 60 days for insured groups, effective March 17.
  • Waived cost-sharing requirement for COVID-19 testing on all plans.
  • Permitting early prescription refills during the public health emergency.

United Healthcare

  • Special enrollment period available March 23, 2020 – April 6, 2020, for individuals who are not enrolled in the Plan, or who previously elected self-only coverage and desires to add eligible dependents.
  • Individuals with OptumRx pharmacy benefits may request an early refill of medications.
  • Cost-sharing is waived for COVID-19 testing for Medicare Advantage, Medicaid, and employer-sponsored plans.
  • UHC Small Group ( under 100/PRIME Platform): For Small Group customers that need a 60 day grace, the customer must contact their Strategic Account Executive or Billing Analyst to be put on the Do Not Term list. For Small Group customers that have not paid as 3/27/20, UHC will be making outbound calls to prevent auto-terms.

For more information on evolving carrier offerings in the wake of the COVID-19 pandemic, visit our 
OneDigital Coronavirus Advisory Hub, or reach out to your local OneDigital advisory team.