March 26, 2020

As a result of the impact the COVID-19 pandemic is having on the workplace, BlueCross BlueShield of South Carolina (BlueCross) and BlueChoice HealthPlan of South Carolina, Inc. (BlueChoice®) provide this update on Group Eligibility Rules and Guidelines for our Fully Insured Group Lines of Business.

While many questions we have been receiving are addressed by our respective standard Premium Billing & Payment guidelines, we understand the need to remain flexible during this extraordinary time. As demonstrated during the 2008 financial crisis, we worked alongside our customers to keep individuals insured. As we have also demonstrated during recent hurricanes and other natural disasters, should local or federal authorities provide new or “emergency” guidelines or provisions, we will amend our policies consistent with such guidance.

To date, most inquiries have been related to eligibility and the “actively at work” provisions of our contracts. To clarify how we are determining eligibility during this time, we offer this guidance:

Actively At Work

BlueCross and BlueChoice understand that employers may need to displace workers and amend work schedules during this crisis. Effective through May 31, 2020, BlueCross and BlueChoice will deem an employee to be actively at work, for eligibility purposes, so long as the employer:

• Considers the employee to be "employed",
• Is collecting contributions toward insurance, unless 100 percent company paid, and
• Is paying the insurance premiums for that employee in a timely manner.

Coverage must continue to be offered on a uniform, non-discriminatory basis to all employees and employee contributions must be no greater than those in effect immediately prior to March 1st, 2020.

Group Size

BlueCross and BlueChoice understand that some groups may lay offworkers or downsize. Effective through May 31, 2020, the group will remain active with BlueCross or BlueChoice at the group’s current premium structure and/or rating methodology unless and until the group’s renewal as long as:

• At least two full-time employees remain on the group policy, 
• The group is collecting contributions toward insurance, unless 100 percent company paid, and 
• Is paying the insurance premiums to BlueCross for those employees in a timely manner, 

Coverage must continue to be offered on a uniform, non-discriminatory basis to all employees and employee contributions must be no greater than those in effect immediately prior to March 1, 2020.

Renewals

BlueCross and BlueChoice will continue to meet market and regulatory provisions for offering timely renewals. Unless any temporary impacts to group size are sufficiently significant and anticipated to be permanent, or the group’s average number of employees on business days in 2019 changed by a sufficiently significant amount from 2018 to cause the group’s market segment to change (from large to small), the group will be renewed under the rating methodology in place at the time of the last renewal. 

COBRA and Continuation

Generally, employers with greater than 20 lives will qualify to offer COBRA coverage to displaced employees while employers with fewer than 20 lives may qualify for state continuation coverage. Additionally, BlueCross and BlueChoice can offer individual coverage options to displaced workers. Please contact your marketing representative to review options.

Returning Employees

Employees rehired or returning to full time status on or before May 31, 2020, will not be subject to a waiting period.

Helping Employees Find other Insurance Coverage

If individuals lose coverage due to a loss of eligibility, BlueCross and BlueChoice will work with agents and employers to assist with transitions to other types of coverage. We can help assess options and eligibility for Medicare, Medicaid, individual coverage or even short-term products.