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Health Carrier COVID-19 Premium Credits

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The COVID-19 pandemic has significantly decreased health care utilization, as health care providers and patients have canceled appointments and postponed elective procedures. Because employees are not using their insurance benefits, some group medical, dental and vision carriers are providing employers with a credit against future premiums owed under their insurance contracts.

Employers receiving these premium credits should consider their obligations under the Employee Retirement Income Security Act of 1974 (ERISA) and/or state guidelines when determining how to apply the credits. For example, any credit amount that qualifies as a plan asset under ERISA must be used for the exclusive benefit of the plan's participants.

Read the rest of the article:
Premium Credits Related to COVID-19
Hylant | Jun 2020

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Additional Articles

If the employer pays 100% of the premiums for employees and their dependents, the employer can keep the credit and use it for any business purpose. Easy. But if employees contribute to the monthly premium cost, which is the more common scenario, it may not be possible for the employer to simply retain the credit.
COVID-19: How Should Employers Handle Carrier Premium Credits
Graham Co. | Jun 2020

When asking how these premium credits should be treated by the employer, we often compare then to the ACA's medical loss ratio (MLR) rebates.  While these premium credits are not MLR rebates, a similar decision must be made to determine whether they, like MLR rebates, are ERISA plan assets.
Carrier Premium Credits and ERISA Fiduciary Obligations
Alera Group | May 2020

No specific guidance was provided for passing through premium contributions in the Notice. However, it is reasonable to rely on the extensive guidance provided for Medical Loss Ratio (MLR) rebates under the ACA.
COVID-19 Premium Rebates: What You Need to Know
Vita Companies | Jun 2020

Related Reading

What Employers Should Do With Their Group Health Plan Rebate
Neider Boucher | May 2020

Index of COVID-19 Express Requests

Reopening Your Workplace

Reopening Your Workplace: Overviews
Masks/Face Coverings in the Workplace
Tips for Wearing a Mask in Summer
Recalling/Rehiring Employees
When Employees Refuse to Return to Work
Addressing Fears About Returning to the Workplace

Testing | Screening | Diagnosis
Testing Employees for COVID-19
Taking Employee Temperatures
Antibody Testing (or Not)
Responding to Employee's COVID-19 Diagnosis
Contact-Tracing in the Workplace
New OSHA Guidance on Recording COVID-19 Cases

Employee Relations
Updating an Employee Handbook for COVID-19
Combatting Zoom Fatigue
COVID-19 Liability Waiver Considerations
Encouraging Employees to Take Time Off
Vacation Policy Changes Amid Pandemic
Heat Illness Prevention Amid COVID-19
Accommodating Workers at Higher Risk for Severe Illness
COVID-19 Myth Busters
EEOC Updates Coronavirus-Related Guidance
Communicating with Employees

Remote Workers
Allowing Telework
Engaging Remote Workers
Remote Work & State Tax Issues
Monitoring Remote Workers

Talent Acquisition
Virtual Onboarding
Preemployment Background Checks During COVID-19
Completing Form I-9 for Remote Workers
Documenting an Expired Driver's License on I-9 and E-Verify
Executive Order Restricts Employment-Based Immigration

Families First Coronavirus Response Act (FFCRA)
FFCRA: School Reopening (or Not) Plans
General (Overviews, DOL Resources, More)
Summer Child Care
Employers' Frequently Asked Questions
IRS FAQs on Tax Credits & Required Documentation
Decision Flow Charts
Valuing Health Plan Costs for Tax Credits

Coronavirus Aid, Relief and Economic Security (CARES) Act
Overviews of Implications for Employers
Employee Retention Tax Credit
Business & Nonprofit Relief
Direct Payments to Individuals (Stimulus Checks/Direct Deposit)
Employee Benefit Plan Provisions
Paycheck Protection Program (Loan Forgiveness)
Unemployment Expansion & Extension
Potential Relief for Government Contractors
Valuing Health Plan Costs for Tax Credits

Compensation and Benefits
Workers' Payroll Tax Deferral
Virtual Benefit Fairs
Health Carrier COVID-19 Premium Credits
COBRA Deadlines Temporarily Extended
Various Benefit Plan Deadline Extensions
Survey Reports: Pay Adjustments Amid COVID-19
Families First Coronavirus Response Act (Paid Leave; Enhanced FMLA; More)
USERRA and COVID-19
Reducing Employer's Retirement Plan Contribution/Match
U.S. Wage and Hour Issues
Making Tax-Favored Disaster Relief Payments to Employees
Leave Donation Programs
IRS Relaxes HDHP Rules

Layoffs and Alternatives to Layoffs
Pay Reductions
Shared-Work/Work Share Programs
Layoff Alternatives
Worker Adjustment and Retraining Notification (WARN) Act
Please also see under CARES Act (above):
Employee Retention Credit
Paycheck Protection Program

Essential Businesses and Workers
Essential Business Designation
Essential Workers: Identifying

General
Employer Resource Centers (U.S. and Global)
Preparedness Plan
Beware Phishing Scams

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