Here you will find answers to frequently asked questions by employers about the impact of the global Coronavirus pandemic (COVID-19) on insurance benefits.
Questions? Please send your questions or feedback to the ETF Employer Services WRS Unit at ETFSMBEmployerInsurance@etf.wi.gov.
Q. What will the impact be on employee benefits for employees who are furloughed for a period of time?
A. If the employee remains active and is not terminated from employment, the employee will retain their benefits.
- Wisconsin Retirement System Benefits – For furlough and other WRS-related benefit questions during this time, please see the Q&A for Employers: WRS Benefits and COVID-19.
- Health Insurance – The employee will continue health insurance coverage with the employer contribution. The employee must still pay the employee contribution. A state or university employee can use sick leave as credits to pay for their portion of premium during a layoff or furlough. The sick leave allocation in these cases is managed by the employer.
State employees: The employer contribution is available for the first three months of layoff for which premiums have not already been deducted. After that, the employee is responsible for the entire premium. The state employee may continue coverage for up to five years using converted sick leave to pay premiums until the sick leave credits are exhausted, followed by 36 months under continuation provisions.
Local employees: The payment of premium share under furlough will be subject to the policies of the local employer.
- Life Insurance – An insured employee my continue coverage during any approved unpaid leave of absence for up to 36 months. In order to continue the insurance in force during an approved unpaid leave of absence, the employee must contact the employer to make premium payments during the leave of absence. Premium contributions must be paid in advance and each payment must be received by the employer at least 31 days prior to the end of the month for which premiums had previously been paid.
The amount of insurance for an employee on an approved unpaid leave of absence is the same as that in effect immediately preceding the approved leave of absence. Initial coverage or increased coverage is not available during the leave of absence. Insurance coverage will lapse for employees who do not wish to continue insurance in force or who do not make arrangements to pay premiums during the leave of absence. An employee who returns from a leave of absence, during which time coverage lapsed, as an eligible employee will have 30 days to apply for the plans and amounts in effect prior to the leave of absence. For more information, see the The Wisconsin Public Employers Group Life Insurance Program (ET-2101) brochure.
- Income Continuation Insurance (ICI) for State and Local – Under the terms of the ICI plan, if an employee is furloughed (or temporarily laid off, but retains WRS coverage), they may continue ICI coverage by making timely payments to their employer (i.e. prior to coverage lapsing). State employees are eligible for the employer share of premiums for the first three months they are furloughed.
If an ICI-covered employee becomes disabled while they are furloughed, they would be eligible for benefits if they meet the necessary criteria, just like if they were working. If the employee allows coverage to lapse by not making premium payments, they can re-enroll within 30 days of returning to work.
Note: If an employee proactively cancels their coverage by completing an ICI application, they will lose their re-enrollment opportunity upon return to work. If they do not want to continue their ICI coverage while furloughed, but want to reinstate coverage upon return to work, they should just let their coverage lapse.
It should be noted that the local Wisconsin Public Employer (WPE) ICI Program is currently on a premium holiday so any employees of local governments who are furloughed are not responsible for paying monthly premiums.
If an employee is laid off and loses WRS coverage during the layoff (i.e. they are terminated), they would no longer be covered under the ICI program. However, they would have a new enrollment opportunity if/when they are rehired.
- Supplemental Insurance – To continue benefits during a furlough, the employee must pay the monthly premium to the employer or payroll center, who will submit the payment to the supplemental vendor.
Employers may arrange to collect payments in advance for up to three months of premiums, using payroll deduction (to preserve the pre-tax opportunity).
If an employer sends a lump-sum payment to the vendor in advance of premium due dates, the employer must clearly identify the months of coverage the lump-sum payment represents.
If the payroll center’s payment system allows, the employer may hold the personal checks and apply them to the remittance to the vendor in the month due.
Q. What if I cannot get the employee’s signature on their health insurance application? (3/27/2020)
A. During Governor Evers' Emergency Order 12, Safer at Home, a secure email from the employee stating their intent to apply for health insurance or change their coverage along with a complete health insurance application provided to ETF in the normal manner shall be acceptable. This accommodation is only available while the Safer at Home order is active and should not be used to create precedent or a new procedure. If you have questions about sending a secure email, please contact ETF at 1-877-533-5020.
Q: Does ETF have any advice regarding COVID-19 antibody testing? Will the testing be covered by insurance? (6/5/2020)
A: All group health insurance health plans will cover antibody testing under certain circumstances at no cost to members. We cannot guarantee that a health plan will reimburse for the services provided by a non-network third-party provider. The member should contact their health plan for specific information.
The FFCRA and CARES Act signed in March require all group health insurance plans to provide coverage at no cost for plan members. This includes “in vitro diagnostic tests,” which CMS indicates include serological/antibody tests. ETF-administered group health insurance health plans must follow this rule. However, plans can require that members seek care in network. If a member is seeking an antibody test, the best way to ensure this test will be covered at 100% is to contact their physician and discuss how to get tested. Members should contact their health plan for detailed cost information.
2019 Wisconsin Act 185 requires the State of Wisconsin Group Health Insurance Program (GHIP) to cover services provided out-of-network if a member is not able to receive those services in-network due to a surge in need. No GHIP health plans have indicated that they are unable to meet current capacity and statewide reported numbers indicate that all hospitals are able to meet current need. ETF at this point would not require plans to reimburse for these services out-of-network. If the health plan does reimburse for the test, they may reimburse whatever their usual and customary rate is for the service, which may be lower than the billed amount.
Finally, any testing that is required by an employer solely as evidence of disease state prior to return to work—either diagnostic or antibody—is not covered under the GHIP. Details are available in the Certificate of Coverage for each plan design.
Q: If an employer requires their employees to be tested for COVID-19 and they test positive or are asymptomatic, will insurance cover treatments? Would the test be considered elected versus necessary? (6/5/2020)
A: Testing that is required by an employer for return to work purposes is not covered by the group health insurance program. The employer must pay the entire cost of any employer-required tests.
If a member seeks a test from their physician as a part of a doctor’s visit (e.g., annual exam, problem-focused visit, visit for symptoms, etc.), those tests would be covered by the health plan.
If an employee tests positive but is asymptomatic, it is unclear what treatment they would be seeking. If the employee became symptomatic and needed to be hospitalized, etc., then those services would be covered under the health plan, regardless of who did the initial testing.
Health Insurance for State Employers
Q. Are we going to be expected to bill people for their insurance benefits once on unpaid leave or are there options to arrange payment plans? (3/27/2020)
A. Please contact the Division of Personnel Management (DPM).
Q. Due to everyone working remotely, our state agency cannot view documents, such as birth certificates, in person for authentication. Will it be acceptable to still send a copy of the documents even though we can’t view them in person? (4/1/2020)
A. ETF will temporarily allow a copy of a birth certificate to be sent to ETF without verification that the employer has viewed the original birth certificate, as to not hold up coverage. However, ETF will require the employer to view the original birth certificate and resend with a statement of verification when the Safer at Home order is no longer in place. This is not a policy change but only a temporary measure due to the Safer at Home order.
Flexible Spending Account (FSA) for State Employees
Q: Due to COVID-19, our employees are at home and do not have access to a printer to print and sign applications for FSA. Will it be acceptable to send a completed application without a signature? (4/8/2020)
A: ConnectYourCare (CYC) does not receive the HSA FSA enrollment forms since the payroll center submits enrollment data over the file interface. The stamp of the received date and postmark is acceptable as an electronic signature for HSA FSA enrollment confirmation during this time. Postmark dates within 30 days of enrollment, but received past the 30 days of election period, should still be acceptable.
Income Continuation Insurance (ICI)
Q. If a covered employee must stay home due to COVID-19 because they are considered a high-risk individual, would they qualify for ICI after meeting the elimination period? (4/1/2020)
A. No, they are not eligible for ICI benefits because they are not disabled due to an illness or injury.
Q. If a covered employee is quarantined due to exposure to someone who tested positive for COVID-19, are they eligible for ICI benefits? (4/1/2020)
A. Since the current quarantine period is 14 days, the employee would not meet the 30-day elimination period (or longer for local employees and UW faculty/academic staff) to be eligible for an ICI benefit. However, if the employee contracts the disease prior to completing the quarantine period, their elimination period for ICI purposes would begin on the first day they were quarantined.
Q: When will I get my annual 40.65 tax and income certification? (6/5/2020)
A: Normally this mailing goes out May 1, however, due to the pandemic and the IRS tax deadline extension to July 1, ETF expects to mail these out in early July.