Benefit and deadline changes due to COVID-19 - Human Resources at Ohio State

COVID-19 HR RESOURCES:

Benefit and deadline changes due to COVID-19

The below information should be read in conjunction with COVID-19-related updates that have already been incorporated into the 2021 Specific Plan Details (SPD) document for the applicable plan and the following Summary of Material Modifications (SMM): SMM issued April 30, 2021 (FSA and HRA changes), SMM issued March 4, 2021 (Benefit and deadline changes) and SMM issued June 20, 2020 (Benefits changes and extended deadlines). The changes detailed on this page are:

Note, as the pandemic and the government’s response (legislation and additional guidance) evolve, additional changes may be made.

Deadline extensions clarified

Ohio State’s Faculty and Staff Health Plan, Dental Plan, Vision Plan, Flexible Spending Account (FSA) and Disability Program

The federal government released rules last year that required employers to extend deadlines for certain actions if they occurred during a one-year period beginning on March 1, 2020. The latest guidance issued late in February 2021 provides an extension that differs by individual and is based on the earlier of (1) one year, or (2) the end of the Outbreak Period (i.e., the 60th day after the end of the National Emergency) for the following actions:

  • Requesting special enrollment changes to medical, dental and vision benefits due to marriage, birth, adoption, placement for adoption, divorce, loss of other group health insurance and loss of Medicaid or Children’s Health Insurance Program (CHIP)
  • Filing claims for medical, prescription drugs, dental, vision, long-term and short-term disability
  • Appealing adverse benefit determinations for medical, prescription drugs, dental, vision, long-term and short-term disability
  • Requesting an external review for medical, prescription drugs, dental, vision
  • Providing notice of a COBRA qualifying event due to divorce, loss of dependent status, or determination of disability by Social Security
  • Electing COBRA continuation coverage
  • Paying COBRA premiums (note, claims incurred after the paid-to-date-of-coverage will be denied unless and until the applicable COBRA premiums have been paid)

The individual deadline extensions create significant operational challenges in our plans. The university is working closely with our administrators to implement them swiftly, but you may experience slight delays while we calculate your individual election and extension periods.

Deadline examples for a special enrollment change
Birth of a child example: Your child was born on 6/1/20. Your deadline to enroll in health coverage is extended for one year from that date, or through 5/31/21. You then have the normal 30-day enrollment period under our plan, making the deadline by which you must make any enrollment election 6/30/21.
Birth of a child example: Assume that an announcement of the end of the National Emergency is made on 7/1/21. Because the Outbreak Period is defined as 60 days after the end of the National Emergency, the Outbreak Period will end on 8/30/21. Your child was born on 11/1/20. Since the end of the Outbreak Period is earlier than one year from the qualifying event on 11/1/20, the Outbreak Period date of 8/30/21 is the end of your extension to enroll your child. You then have the normal 30-day enrollment period under our plan, making the deadline by which you must make any enrollment election 9/29/2021.
Deadline examples for electing COBRA continuation coverage
COBRA election example: Your COBRA election period began 6/30/20. Your deadline to elect COBRA is extended for one year from that date, or through 6/29/21. You then have the normal 60-day election period, making the deadline by which you must elect COBRA 8/28/21.
COBRA election example: Assume that the announcement of the end of the National Emergency is made on 7/1/21. Because the Outbreak Period is defined as 60 days after the end of the National Emergency, the Outbreak Period will end on 8/30/21. Your COBRA election period began on 11/1/20. Since the end of the Outbreak Period is earlier than one year from your election deadline, the Outbreak Period date of 8/30/21 is the end of your extension to enroll in COBRA. You then have the normal 60-day COBRA election period, making your deadline 10/29/21.

For questions regarding special enrollment contact HR Connection at hrconnection.osu.edu or (614)247-myHR (6947).  For all other questions contact the appropriate plan administrator:

  • Medical claims, appeals or external review – contact Trustmark at 800-678-6269
  • Prescription drug claims, appeals or external review – contact Express Scripts (ESI) at 866-727-5867
  • Dental claims, appeals or external review – contact Delta Dental at 800-524-0149
  • Vision claims, appeals or external review – contact Vision Service Plan (VSP) at 800-877-7195
  • Disability claims or appeals – contact Unum at 866-679-3054
  • COBRA notices, elections, or payments – contact Trustmark at 866-433-0318 ext. 44124

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FSA deadline extensions

Ohio State’s Flexible Spending Accounts (FSA)

Deadlines for the 2020 Health Care and Dependent Care FSA plan year have been extended. The period of time in which you can incur expenses and file for reimbursement have been extended through December 31, 2021 as long as you remain employed by Ohio State. Because the date to incur an expense and to file for reimbursement are the same (December 31, 2021), you should try to plan for services to occur early enough in 2021 to allow sufficient time to submit a request for reimbursement before the deadline. You may use your TASC Card for any known expenses through December 31, 2021.

If you leave Ohio State prior to December 31, 2021, expenses must be incurred prior to your termination date to be eligible for reimbursement, but the claims filing deadlines outlined in this document will apply. Your reimbursable   balance is limited to actual contributions, less reimbursements received at the time of termination of OSU employment.

The FSA deadlines for the 2021 plan year will not be extended. Therefore, if you determine during 2021 that you will not have sufficient expenses to be reimbursed for your entire plan year election, note below the permissible mid-year changes without a qualifying event and ensure you take any action needed to reduce your risk of forfeiting 2021 FSA balances on March 31, 2022.

The previous extension of the FSA filing deadline for the 2019 plan year will end on March 31, 2021.

See the chart below to illustrate applicable deadlines for FSA plan years 2019, 2020 and 2021:

Plan Year Claims Incurred Beginning Claims Incurred Ending Reimbursement Filing Deadline
2019 January 1, 2019 March 15, 2020 March 31, 2021
2020 January 1, 2020 December 31, 2021 December 31, 2021
2021 January 1, 2021 March 15, 2022 March 31, 2022

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Dependent Care FSA maximum age for dependent children

Although current rules limit reimbursement of qualifying dependent care expenses to children under age 13, the Consolidated Appropriations Act, 2021 (CAA), provides an extra year for children who aged out during the 2020 plan year. If you enrolled prior to January 31, 2020, you can be reimbursed for claims incurred on behalf of a 13-year-old child during the entire 2020 plan year. If you had a balance remaining, that child’s claims may be incurred through the child’s 14th birthday and must be filed for reimbursement by December 31, 2021.

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Mid-year FSA decreases without a qualifying event

Ohio State’s Flexible Spending Accounts (FSA)

Beginning March 2021, you can elect a prospective decrease to your 2021 FSA elections without a qualifying event. Decreases are subject to the following:

  • Health Care FSA contribution decrease (no refund of prior contributions)
    • You cannot decrease your annual election to an amount below what you have already contributed or been reimbursed, whichever amount is greater.
    • The decrease in your contribution amount will occur with the beginning of the first pay period following receipt of the form by the Office of Human Resources.
    • You are limited to one mid-year Health Care FSA decrease in 2021 without a qualifying event.
    • Your request for a decrease must be received by the Office of Human Resources prior to December 1, 2021.
  • Dependent Care FSA contribution decrease (no refund of prior contributions)
    • You cannot decrease your annual election to an amount below what you have already contributed.
    • The decrease in your contribution amount will occur with the beginning of the first pay period following receipt of the form by the Office of Human Resources.
    • You are limited to one mid-year Dependent Care FSA decrease in 2021 without a qualifying event.
    • Your request for a decrease must be received by the Office of Human Resources prior to December 1, 2021
Examples and instructions on how to decrease your 2021 Flexible Spending Accounts (FSA)
Election example: Assume you made a $1,200 health care FSA election for 2021 and have had $100 in payroll contributions and $300 in reimbursements year to date. You have determined that your annual election is greater than the amount that you now expect to incur in eligible expenses, and you are concerned that you will have to forfeit any remaining funds. Even though you have not had a qualifying event in the last 30 days, you may elect to decrease your annual election amount to an amount that is no less than $300 for the rest of 2021.
Instructions to stop or decrease future FSA contributions: Complete the Flexible Spending Account (FSA) Election Form. Complete Section 1. In Section 2, mark “Other” and write “Decrease FSA Annual Election without a Qualifying Event” and indicate if the request is for a Health Care or Dependent Care Account. In Section 3, indicate the total amount you elect to contribute for the entire 2021 plan year. Sign and date the completed form. You cannot make changes online through Workday. Requests must be received by the Office of Human Resources prior to December 1, 2021.
Contribution change effective date: The change in your contribution amount will occur with the beginning of the first pay period following receipt of the form by the Office of Human Resources.

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Coverage of prevention services and vaccines for Coronavirus

Ohio State’s Faculty and Staff Health Plan

During the public health emergency for COVID-19 and as recommended by the governing preventive service agencies, coronavirus preventive services will be covered at 100% with no out-of-pocket costs or network restrictions.  These services include an item, service or immunization intended to prevent or mitigate the coronavirus disease and that is:

  • An evidence-based item or service that has in effect a rating of “A” or “B” in the current recommendations of the U.S. Preventive Services Task Force; or
  • An immunization that has in effect a recommendation from the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention with respect to the individual involved.

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