FAQs: COVID-19 Update

Things have been changing very quickly with the coronavirus (COVID-19) situation in the United States.  Fighting the spread of COVID-19 is a top priority right now in our country, and this challenge has changed our normal way of life. We’re facing social and economic uncertainty at home, in our country, and globally. But one thing’s for certain: we’re all in this together. That’s why we’re providing you with these Frequently Asked Questions about COVID-19 FAQs and continuous updates.

As a company with steadfast and strong roots since 1916, Mason-McBride has weathered storms through tumultuous and historical times throughout the decades: wars, the Great Depression, economic uncertainty, 9/11, and now, COVID-19. While we’ve been tested in the past as well as the current day, our spirit remains strong, and we want you to know and to reassure you that we remain here for you.

We understand the impact that flattening the COVID-19 curve has on our clients. We want you to know how much we appreciate your flexibility and understanding as we contact our carriers on your behalf who are working differently in light of the current situation. Response times may be slower than normal, and we completely understand your frustration. But rest assured, we are doing everything we can to be as responsive as possible to your questions, concerns, and needs during this fluid and ever-changing point in our history.

We look forward to returning to the time where we can live our normal way of American life.  Until that time, please take care of yourselves, your loved ones, and be kind to others who may need help.

Sincerely yours,
W. Michael McBride
President


Is Mason-McBride Still Open?

Yes, our office remains open to service and support all of our clients, from Commercial Lines to Personal Lines to Group Benefits.  We are here to answer your questions and concerns.  Please be aware that while we are working with insurance carriers, their workflows and office situations have changed too, and there might be a longer than usual response time.  We understand your frustration, but we are doing everything possible to obtain the information you need as soon as possible.

Rest assured, we are taking all precautions and following guidelines announced by the CDC to keep our staff safe and healthy, including frequent sanitation at designated intervals, social distancing, and requesting that if anyone falls ill, that they remain at home.  Regarding in-person meetings, we’ll follow your lead and your wishes.  Just let us know.

Review MMC’s Executive Order Exception 3-24-2020


What’s happening with health insurance carriers and other benefit providers?

As we’ve seen during the past few weeks, the COVID-19 situation is extremely fluid.
We’ll update this page as we receive updated information.

Here’s where you can find the most accurate, current information from various carriers:

Aetna

Aflac

All Savers — Setting up a “Healthiest You” Account

Ameritas

Avēsis
In response to current events, we are extending our premium grace periods to groups. Through May 31st, Avēsis clients will be granted an additional 30 days of grace period beyond current policy limits. For example, if your grace period for payment has been 30 days, it will now be extended to 60 days.

Assurant

Basic

Blue Cross Blue Shield of Michigan/Blue Care Network

Cigna

Cincinnati

Colonial Life

Dearborn National

Delta Dental

Delta Dental of Michigan, Ohio, and Indiana:  They are extending a 60-day grace period to all of their customers for their April premium or administrative fees during this challenging time.

Employee Benefits Corporation

EHIM

Eyemed

  • Eyemed Member Benefits FAQ
  • Eyemed:  Should you need glasses or contacts while social distancing, please remember you can use your in-network benefits from the comfort of your home at participating online providers. Benefits are applied automatically, and glasses will be delivered right to your home. Under the circumstances, many of these online providers are offering free expedited shipping and no-cost returns for extra convenience.*
  • If you do choose to visit a provider in person, we recommend calling your provider directly to verify amended store hours or closing. You have 24-hour access to the Provider Locator. Customer Care Center: 1.866.939.3633.

Guardian

The Hartford

Health Alliance Plan

HealthEquity

Humana

Humana Employer FAQs

Humana Employer Info Hub

John Hancock

Liberty Union

Lincoln Financial

McLaren Health Plan

MetLife

Mutual of Omaha

Priority Health

Priority Health — for Employers

Priority Health — for Members

Principal

Reliance Standard

Sun Life

Symetra

Total Health Care

  • Total Health Care pays $45 copay for Teladoc for all non-HDHP plans all of the time.
  • Total Health Care will provide health insurance benefits to employees who are laid off due to the Coronavirus when the employer continues to pay their health insurance premium.  The employer must provide coverage to all laid-off employees and not pay premiums on select individuals.  If an employer is not willing to pay the premium for a laid-off employee, then they can select COBRA if they are eligible.
  • In response to the rapid spread of the Coronavirus COVID-19, Total Health Care is relaxing restrictions on early prescription refills effective immediately. In the event a prescription is rejected because it is being refilled too soon, pharmacists in Michigan are authorized to override the rejection immediately.

Trustmark

Superior Vision

Ulliance

United Healthcare

United Healthcare Cost-Sharing Updates for COVID-19

Unum

Unum has a dedicated email for COVID-19-related questions: COVID19questions@unum.com.

VSP


Information directly from Blue Cross Blue Shield of Michigan / Blue Care Network: frequently asked questions about coverage, rates, and membership in light of COVID-19 (for Commercial and Medicare Advantage groups) (added 3/23/20)

Question: Will Blue Cross Blue Shield of Michigan and Blue Care Network allow employers to extend coverage to their employees who are affected during temporary closures or are temporarily laid off or have temporary reduced hours?
Answer: Yes, Blue Cross and BCN will allow extension of coverage for all group sizes provided premiums are paid based on current payment policies. Paying the premium is all that is required; no need to submit additional paperwork for current employees.
The following would apply:
• The employer still considers the individual an employee and therefore eligible for coverage under the group’s plan.
• The employer maintains premium payments.
• The employer should notify the employee that benefits would be maintained for a specified number of months.
• If the employee does not return after the specified period, the group would proceed with the normal loss of coverage/termination process.

Question: What is the standard employer premium payment grace period and are you making any changes to that policy?
Answer: Blue Cross and BCN will continue with our current grace periods – for fully insured customers this is a 30-day grace period. We recognize, however, that COVID-19 is rapidly changing our health care ecosystem and we will continue to assess our approach.

Question: Will Blue Cross and BCN allow employers to modify open enrollment, new hire, reinstatement policies after returning from furlough?
Answer: Yes, Blue Cross and BCN will allow and is willing to waive waiting periods. Groups can re-add employees through the usual membership processes.

Question: Will Blue Cross and BCN re-rate experience-rated insured coverage or stop loss for changes in contracts or other fluctuations in eligibility that are driven by responses to the COVID-19 pandemic?
Answer: We realize that there may be several types of unique eligibility changes that occur in the near-term in response to COVID-19. To avoid creating concerns for our group customers we will place a temporary hold on our re-rating practices related to large changes in enrollment until further notice.

Question: For customers that are experiencing a change in membership due to COVID-19, will Blue Cross and BCN allow the employer to self-adjust their bill?
Answer: Group customers or agents should not self-adjust the bill. Membership changes will automatically be applied in the group’s next billing cycle. If there is more than a 25% change in the group’s fully insured membership, groups should work with their managing agent or Blue Cross account representative before the due date.

Note from Mason-McBride: Additionally, any questions about cost-sharing with employees during this time will need to be directed to your attorney and/or CPA.


BCBSM/BCN remains open during stay-at-home directive (added 3/23/2020)

Here’s the latest communication from BCBSM/BCN’s Executive Vice President, Kenneth Dallafior.


BCBSM/BCN Helpline and E-mail specifically for small group employers

To help employers navigate these difficult times, Blue Cross Blue Shield of Michigan and Blue Care Network have established a helpline and mailbox to field inquiries from small group customers. The purpose of the helpline and mailbox is to assist with Blue Cross Blue Shield of Michigan’s policies, small business resources, requests for support and other issues connected to COVID-19.

Please note: The helpline and mailbox aren’t intended for questions related to claims or health care treatments. Those inquiries should continue to be directed to Blue Cross and Blue Care Network’s Customer Service centers.

Small group COVID-19 helpline: 1 (866) 582-5052 from 8 a.m. to 5 p.m. ET, Monday through Friday.
Email inquiries: smallgroupcovid19@bcbsm.com


Blue Cross Blue Shield of Michigan members will have COVID-19 testing and treatment provided at no cost, expanded telehealth services (added 4/3/2020)

Blue Cross Blue Shield of Michigan and Blue Care Network are expanding coverage for services related to COVID-19:  waiving all member copays, deductibles, and coinsurance for COVID-19 testing and treatment. They are also expanding no-cost telehealth services to include common behavioral health therapy services.

The coverage is effective immediately and applies to all individual medical, Medicare Advantage, and Medicare Supplemental plans.

For COVID-19 testing and treatment
• BCBSM and BCN will waive member cost-sharing for physician-authorized COVID-19 testing. In line with the Families First Coronavirus Response Act, COVID-19 testing and all services that result in ordering or administration of a COVID-19 test will be covered without member cost-share as of March 18, 2020. Testing and associated services must be consistent with CDC guidelines.
• Blue Cross will waive member cost-sharing for all COVID-19 treatment through June 30, 2020. Blue Cross will cover, with no member cost share, all COVID-19 treatment provided to members on an inpatient or outpatient basis, from both in-network and out-of-network providers.

For telehealth services
• BCBSM/BCN is extending no-cost telehealth services to members with existing telehealth benefits through at least June 30.
• BCBSM/BCN is expanding these services to include common behavioral health therapy services in addition to including some of the most common office visits and hospitalization follow-ups.
• These changes apply to care received through in-network providers as well as care received through Blue Cross Online Visits and are effective as of March 16.


HAP Members – Free Home Delivery Service for Prescription Drugs

HAP’s FREE home delivery service for prescription drugs through Pharmacy Advantage saves members time while making life easy and safe.

WHO DOES THIS APPLY TO?
• All HAP members

WHAT SERVICES ARE AVAILABLE THROUGH PHARMACY ADVANTAGE?
• Free delivery service, including out of state
• Up to a 90-day supply of most medications
• Same day medication fill
• Refill reminders and auto-shipment
• Assistance for medication changes or prior authorizations
• Assistance from health experts about medications

HOW IS HAP ENSURING ITS MEMBERS HAVE AN ADEQUATE DRUG SUPPLY ON HAND?
• Early refills
• FREE home delivery service through Pharmacy Advantage

HOW CAN MEMBERS ENROLL FOR FREE HOME DELIVERY THROUGH PHARMACY ADVANTAGE?
There are three easy ways:
• Visit hap.org/delivery and click on Sign Up.
• Fill out the form at hap.org/delivery.
• Call (800) 456-2112, Monday through Friday, from 8 a.m. to 6 p.m.

IS THERE MESSAGING I CAN SHARE WITH EMPLOYEES?
The following messaging can be shared:

HAP is here, offering all HAP members FREE home delivery for prescription drugs.
Members-only pay their prescription copay.
Save time while making life easy and safe. Use Pharmacy Advantage service to get:
• Free delivery service, including out of state
• Up to a 90-day supply of most medications
• Same day medication fill
• Refill reminders and auto-shipment
• Assistance for medication changes or prior authorizations
• Assistance from health experts about your medications
To get started, go online to hap.org/delivery or call Pharmacy Advantage at (800) 456-2112, Monday through Friday, from 8 a.m. to 6 p.m.

WHERE SHOULD HAP MEMBERS BE DIRECTED FOR MORE INFORMATION?
hap.org/prescription-drug: information on prescription drug coverage
hap.org/delivery: information on how to get started with home delivery, Frequently Asked Questions (FAQs) and more
• Pharmacy Advantage at (800) 456-2112 Monday through Friday, from 8 a.m. to 6 p.m.
• HAP Customer Service at (800) 422-4641 (TTY: 711), Monday-Friday, from 8 a.m. to 7 p.m.

WHO CAN I CONTACT FOR MORE INFORMATION?
Please email your HAP representative. A contact list can be found
at hap.org/employers/contact.


Health Alliance Plan (HAP) Frequently Asked Questions: Fully-insured group membership and premium payment policies during the COVID-19 situation

Will HAP allow employers to continue health care coverage for currently enrolled employees who are temporarily laid off or have had their hours reduced?

  • Yes, HAP will allow if the employer considers their employees actively employed (whether temporarily laid off or working reduced hours), their coverage can continue.
  • If an employer temporarily “terminates” an employee from their payroll system so that the person can collect unemployment, it is up to the employer to determine if they consider that person an active employee who will be returning to work.  If yes, they can continue their health care coverage.
  • It is up to the employer group to monitor and manage their enrollment.
  • The employer is responsible for continuing to pay the premiums.
  • HAP will re-evaluate these parameters at the end of April.

How will HAP handle new hires that are in their probationary/new-hire period?
The waiting period will not be affected for employees who were in their new hire/probationary period as of March 12, 2020 and are temporarily laid off or their hours are reduced.

If an employer needs to terminate employees temporarily from their health care coverage during this time, can they reinstate the employees’ health care coverage after they return to active employment without satisfying their waiting period?
Yes, when existing employees return to work, we will waive waiting periods for any group that does not have “immediate coverage” for employees indicated in their re-hire policy.

Is HAP allowing a special open enrollment while we are working through COVID-19 issues for those employees who previously waived coverage?
To help employees access care who may have previously waived coverage, we are providing fully insured small group clients the ability to establish a special enrollment opportunity, due to COVID-19, to enroll employees who did not previously enroll.

The opportunity will be limited to employees who previously did not elect coverage for themselves (spouses, children) or waived coverage. The enrollment opportunity will extend from March 24 to April 30, 2020.

What if an employer needs to make enrollment changes due to life events and they are unable to do so right now?
From March 24 through April 30, 2020, an employer may make enrollment changes for employees and their eligible dependents within 60 days.  Employers can continue to send an email with eligibility changes to MB_Enrollment@hap.org or self-serve using the Employer Portal at www.hap.org.

What is HAP’s standard premium payment grace period?
We plan to continue with our grace period as defined today.  For insured employer groups, we have a 30-day grace period.  COVID-19 is impacting us greatly and we will continue to monitor and adjust our approach as we see necessary.

What if employers cannot afford to pay their premiums, due to loss of business or shut down?  Is there any relief?
We are handling this on a group by group basis; the employer group should reach out to HAP to discuss.  We will work closely with our agents and employer partners to determine the best course of action. 

If employers can no longer afford to continue covering their employees, what options do they have?
HAP has individual plans available at hap.org or by calling (855) 948-4427.  Documentation showing loss of coverage will be needed – that can be obtained by calling HAP’s customer service at (313)872-8100.  Employees seeking assistance can go to www.healthcare.gov to find ACA plans that may offer premium tax credits.

Will HAP re-rate experience-rated groups due to fluctuations in eligibility due to the COVID-19 pandemic?
We do expect eligibility changes as a result of COVID-19.  However, we have no plans to re-rate or change established rates due to these eligibility shifts in the short term.


Are telehealth visits a good option to use right now? What’s the cost for this service?

Telehealth visits are a good option to use during this time of the pandemic. Currently, some insurance companies are waiving the co-pays associated with telehealth visits to support the use of these types of services as well as lessen the contact of in-person visits if someone is contagious.

Check with your insurance company’s website for your coverage. Use nurse and telehealth lines when offered by your carrier for you and your covered family members to obtain medical services and advice from the comfort of your own home.

Additionally, we recommend utilizing additional carrier resources, such as member portals and free member mobile applications.


How much does COVID-19 testing cost if I or someone in my family needs to be tested?

We’ve seen most health insurance carriers waive the COVID-19 test fee at this time. Some insurance companies are waving ancillary costs, such as office visits, co-pays, and coinsurance, too. If you have a network plan, be mindful. Utilize participating providers to reduce your costs as well as remove any billing surprises. Note that even if the test fee is waived, you may still be responsible for any lab fees.


My health insurance is with Blue Cross Blue Shield of Michigan or Blue Care Network. What is this carrier doing in light of the COVID-19 outbreak?

We have been in touch with BCBSM/BCN, and they have informed us of web pages they have posted specifically regarding coronavirus:


What about prescriptions for my family and myself? Especially if we have maintenance medications – can I get prescriptions filled early?

Some insurance companies are allowing early refills of prescriptions. Some are 30 days in advance, or even allowing a 90-day supply if using a mail-order program.  Please be mindful so as not to decimate the drug supply. Opioids are not considered for early refills. Check with your carrier for your particular situation.


Will my family or I need any prior authorizations for care?

Some insurance companies are relaxing prior authorization requirements, but we recommend to ALWAYS coordinate with your primary care physician.


Can I be reimbursed for COVID-19 expenses through my Flexible Savings Account (FSA)?

As a general guideline, purchases being made for prevention to reduce the spread of the virus such as face masks, hand sanitizers, and disinfectants will more than likely not be eligible for reimbursement.  On the other hand, first aid kits, steam vaporizers, and thermometers are FSA-reimbursable expenses that may be useful at this time.

It is important to note that each FSA plan is unique regarding what qualified expenses will be reimbursed, so consult your Summary Plan Description (SPD) to know which expenses your plan deems eligible.  Here’s a full list of FSA-eligible items from the IRS. 

Additionally, The FSA Store has created a list of FSA-eligible items to help prepare.


What about disability insurance and COVID-19?

COVID-19 is a completely unprecedented situation. What we’ve seen from carriers is individuals will be considered disabled as long as they meet the definition of disability which may or may not be the same as the quarantine period. Carriers say cases will be evaluated on a case by case basis. Contact us regarding any particular situation.


What if a member of the employee’s household is diagnosed with COVID-19, and then the employee is also quarantined as a precaution, even though they haven’t yet been diagnosed? Is that considered a disability for the employee?

Overall, the answer is no. But again, carriers are evaluating on a case-by-case basis.


Are there changes being made to the Family Medical Leave Act because of COVID-19?

The Mason-McBride staff is working on a summary of the new requirement that was just passed into law the night of Wednesday, 3/18/2020. We will update this information as soon as possible.


Commercial Insurance:  Business Interruption Functions

We have received questions regarding how business interruption functions relate to the current COVID-19 issue. Traditional business interruption insurance coverage requires that the suspension of business must be caused by a direct physical loss of, or damage to the covered property in question.

Also, that loss or damage must be caused or result from a covered cause of loss. In addition, viruses or diseases are not typically an insured peril.

That said, we recommend that any incidents which may or may not arise to a claim status be submitted to the applicable insurance carrier for analysis and determination. Please contact your Account Executive and Account Manager to discuss your particular and specific situation.


What about employee eligibility?

If you have employees that are enrolled on your benefit plans and have exceeded their PTO or are laid off/provided leaves, we recommend consulting legal counsel to obtain guidance about how the definition of reduction in hours may affect their continued eligibility on your various plans.  Technically, once an employee has a reduction in work hours to a certain level, they may no longer qualify for enrollment in the benefit plans and need to be terminated. They would then be eligible for COBRA if your business qualifies to offer COBRA.  Given the unique nature of the current environment consultation with legal counsel is warranted.


The Families First Coronavirus Response Act (FFCRA)

President Trump signed into law, ”The Families First Coronavirus Response Act” (the law) on March 20, 2020. It becomes effective in 15 days, (April 2, 2020). The key employment-related aspects of the law are provided below.

The law provides two leaves, Paid Sick Leave and Paid Public Health Emergency Leave Under the Family and Medical Leave Act. The law only applies to employers with fewer than 500 employees. Part-time employees are included in this count to assess coverage. Further, the below provisions can also be affected by specific state and local laws.

Paid Sick Leave
Employers with fewer than 500 employees will be required to provide full-time employees with 2 weeks (80 hours) of paid sick leave for the following reasons:

  • To self-isolate because of a diagnosis of COVID-19, or to comply with a recommendation or order to quarantine due to exposure or exhibition of symptoms;
  • To obtain a medical diagnosis or care if the employee is experiencing symptoms of the coronavirus;
  • To care for a family member who is self-isolating due to a diagnosis of coronavirus, experiencing symptoms of coronavirus and needs to obtain medical diagnosis or care, or quarantining due to exposure or exhibition of symptoms; or
  • To care for a child whose school has closed or childcare provider is unavailable, due to the coronavirus.

Employers must compensate employees for any paid sick time they take at their regular rates of pay (unless the leave is being used to care for a family member or child, in which case the employee is only entitled to two-thirds of his or her regular rate of pay). The sick leave is available for immediate use by employees, regardless of the length of employment.

Additionally, part-time employees are entitled to the number of hours of paid sick time equal to the number of hours they work, on average, over a 2-week period.

Employers who already provide paid leave to employees on the day before the law is enacted must provide this paid leave in addition to any paid leave already provided-and may not change their paid leave policies on or after the date of enactment to avoid compliance. Finally, employers cannot require employees to utilize other paid leave before using the paid leave provided by this bill.

This part of the law would also expire on December 31, 2020.

Paid Public Health Emergency Leave Under the Family and Medical Leave Act
Employees of employers with fewer than 500 employees can be provided with the right to take up to 12 weeks of public health emergency leave under the Family and Medical Leave Act (“FMLA”).

Ten of these twelve weeks are be paid at a rate of no less than two-thirds of the employee’s usual rate of pay. (FMLA leave for all other purposes remains unpaid.) The first two weeks will be paid by Paid Sick Leave above.

To be eligible for paid leave, employees must have been on the employer’s payroll for 30 days and may use emergency FMLA leave for the following reasons:

  • To care for a child of an employee if the child’s school or place of care has been closed, or the childcare provider is unavailable, due to the coronavirus. The first two weeks of leave may be unpaid; the employee may choose to substitute accrued paid time off or other medical or sick leave during this period, but an employer cannot require an employee to do so. After the first two weeks of unpaid leave, employers must continue paid FMLA leave at a rate of no less than two-thirds of the employee’s usual rate of pay.
  • As with traditional FMLA leave, this leave is job-protected and an employer must return the employee to the same or equivalent position upon their return to work. This new law outlines an exception for employers with less than 25 employees if the employee’s job no longer exists due to the coronavirus pandemic, which requires employers to make reasonable efforts to restore the employee to an equivalent position over a one-year period.
  • The Secretary of Labor has the authority to issue regulations exempting: (1) certain health care providers and emergency responders from taking leave under the bill; and (2) small business with fewer than 50 employees from the requirements of the bill if it would jeopardize the viability of the business. This amendment to the FMLA would expire on December 31, 2020. Within seven days from enactment, the Secretary of Labor will provide a model notice to be posted in areas that are readily accessible to employees (e.g., kitchens and breakrooms) regarding the law. We anticipate direct notice might also be required in the form of an email or letter.Tax Credits for Paid FMLA and Sick Leave and Grant of $1 Billion Dollars for Emergency Unemployment Insurance
    A series of refundable tax credits are for employers providing paid emergency sick leave or paid FMLA. The credits are as follows:
  • A refundable tax credit for employers equal to 100 percent of qualified family leave wages required to be paid that are paid by an employer for each calendar quarter. The tax credit is allowed against the tax imposed on the employer portion of Social Security taxes. The amount of qualified family leave wages taken into account for each employee is capped at $200 per day and $10,000 for all calendar quarters. If the credit exceeds the employer’s total liability for Social Security taxes for all employees for any calendar quarter, the excess credit is refundable to the employer.
    A refundable tax credit for employers equal to 100 percent of qualified paid sick leave wages that are paid by an employer for each calendar quarter. The tax credit is allowed against the tax imposed by the employer portion of Social Security taxes (6.2% of wages).
  • One billion dollars in grants to states for emergency unemployment insurance, half of which would be transferred to the states within 60 days after the enactment of the bill (so long as the state complies with certain requirements, such as requiring employers to notify employees of the availability of unemployment compensation and permitting individuals to apply for unemployment compensation in at least two of the following ways-in-person, by phone, or online). The remainder of the grant would be reserved for states in which the number of unemployment compensation claims has increased by at least 10% over the same quarter in the prior calendar year. To receive access to the second portion of the grant, states must, among other things, make it easier for individuals to obtain unemployment compensation by waiving work search requirements and waiting periods. A copy of the law can be found here.

DOL Issues Guidance on the Families First Coronavirus Response Act (updated 3/25/2020)

The U.S. Department of Labor’s Wage and Hour Division (WHD) announced its first round of published guidance to provide information to employees and employers about how each will be able to take advantage of the protections and relief offered by the Families First Coronavirus Response Act (FFCRA) when it takes effect on April 1, 2020.

FFCRA will help the United States combat and defeat COVID-19 by giving all American businesses with fewer than 500 employees funds to provide employees with paid leave, either for the employee’s own health needs or to care for family members. The legislation will ensure that workers are not forced to choose between their paychecks and the public health measures needed to combat the virus while at the same time reimbursing businesses.

The guidance addresses critical questions, such as how an employer must count the number of their employees to determine coverage; how small businesses can obtain an exemption; how to count hours for part-time employees; and how to calculate the wages employees are entitled to under this law. This is just the first round of information and compliance assistance to come from WHD.

Families First Response Act: Questions and Answers

DOL Provides Second Guidance Questions and Answers

DOL Provides Third Guidance Questions and Answers

Fact Sheet for Employers

Fact Sheet for Employees


Wage and Hour Division, Department of Labor Workplace Poster

Where do I post this notice? Since most of my workforce is teleworking, where do I electronically “post” this notice?
Each covered employer must post a notice of the Families First Coronavirus Response Act (FFCRA) requirements in a conspicuous place on its premises. An employer may satisfy this requirement by emailing or direct mailing this notice to employees or posting this notice on an employee information internal or external website.

Do I have to post this notice in other languages that my employees speak? Where can I get the notice in other languages?
You are not required to post this notice in multiple languages, but the Department of Labor is working on translations.

Do I have to share this notice with recently laid-off individuals?
No, the FFCRA requirements explained on this notice apply only to current employees.

Do I have to share this notice with new job applicants?
No, the FFRCA requirements apply only to current employees. Employers are under no obligation to provide the notice of those requirements to prospective employees.

Do I have to give notice of the FFCRA requirements to new hires?
Yes, if you hire a job applicant, you must convey this notice to them, either by email, direct mail, or by posting this notice on the premises or on an employee information internal or external website.

If my state provides greater protections than the FFCRA, do I still have to post this notice?
Yes, all covered employers must post this notice regardless of whether their state requires greater protections. The employer must comply with both federal and state law.

I am a small business owner. Do I have to post this notice?
Yes. All employers covered by the paid sick leave and expanded family and medical leave provisions of the FFCRA (i.e., certain public sector employers and private sector employers with fewer than 500 employees) are required to post this notice.

How do I know if I have the most up-to-date notice? Will there be updates to this notice in the future?
The most recent version of this notice was issued on March 25, 2020. Check the Wage and Hour Division’s website or sign up for Key News Alerts to ensure that you remain current with all notice requirements: www.dol.gov/agencies/whd.

Our employees must report to our main office headquarters each morning and then go off to work at our different worksite locations. Do we have to post this notice at all of our different worksite locations?
The notice needs to be displayed in a conspicuous place where employees can see it. If they are able to see it at the main office, it is not necessary to display the notice at your different worksite locations.

Do I have to pay for notices?
No. To obtain notices free of charge, contact the Department’s Wage and Hour Division at 1-866-4-USWAGE (1-866-487-9243). Alternatively, you may download and print the notice yourself from https://www.dol.gov/agencies/whd/posters

I am running out of wall space. Can I put the required notices in a binder that I put on the wall?
No, you cannot put federal notices in a binder. Generally, employers must display federal notices in a conspicuous place where they are easily visible to all employees-the intended audience.

We have break rooms on each floor in our building. Do I have to post notices in each break room on each floor or can I just post them in the lunchroom?
If all of your employees regularly visit the lunchroom, then you can post all the required notices there. If not, then you can post the notices in the break rooms on each floor or in another location where they can easily be seen by employees on each floor.

Our company has many buildings. Our employees report directly to the building where they work, and there is no requirement that they first report to our main office or headquarters prior to commencing work. Do I have to post this notice in each of our buildings?
Yes. Where an employer has employees reporting directly to work in several different buildings, the employer must post all required federal notices in each building, even if the buildings are located in the same general vicinity (e.g., in an industrial park or on a campus).

The poster can be found here.


Many Employers Must Offer Paid Leave Under Coronavirus Relief Law

Here’s an article with details from the Society for Human Resource Management (SHRM)


State of Michigan Stay Home Order, EO 2020-21 (updated 3/23/2020)

On March 23, 2020, in order to curb the spread of COVID-19 in Michigan, Governor Whitmer issued Executive Order 2020-21 (“EO 2020-21”), which orders all Michigan residents to stay at home or in their place of residence unless exempted until April 13, 2020, at 11:59 p.m. To this end, EO 2020-21 also orders that no person or entity may conduct a business or conduct operations that require workers to leave their homes or residences unless that entity qualifies for an exemption. Read more details about this Order and its ramifications for businesses’ in-person operations.


IRS Issues Tax Return Filing and Payment Relief (updated 3/24/2020)

The Treasury Department and the Internal Revenue Service (IRS) announced special Federal income tax return filing and payment relief in response to the ongoing Coronavirus Disease 2019 (COVID-19) emergency in Notice 2020-18.

Released at the same time as the notice, the IRS answers frequently asked questions related to the relief provided for filing federal tax returns, paying estimated taxes, contributing to IRAs, HSAs and receiving refunds.

These questions and answers will be updated periodically and are designed to be a flexible tool to communicate information to taxpayers and tax professionals in this changing environment. The answers to these questions provide responses to general inquiries and are not citable as legal authority. Accordingly, the Treasury Department and the IRS are continuing to consider additional IRB guidance on these issues addressed in these FAQs.

Click here for a copy of IRS Notice 2020-18 and FAQs.


Resources for small businesses

https://www.sba.gov/page/coronavirus-covid-19-small-business-guidance-loan-resources

https://sbdcmichigan.org/small-business-covid19/

https://www.detroitchamber.com/small-businesses-what-you-need-to-know-in-the-midst-of-covid-19/

https://sbdcmichigan.org/disaster-loan-help/


Additional relief available to Michigan businesses as loans or grants

The Michigan Economic Development Corporation (MEDC) offers a Michigan Small Business Relief Program, authorizing up to $10 million in small business grants and $10 million in small business loans for emergency relief to businesses directly impacted by the COVID-19 outbreak.  Details and how to apply can be found here.


I have questions not answered here.  What should I do?

Please feel free to contact us at info@mason-mcbride.com or call us directly at (248) 822-7170 to speak to our team to answer your questions specific to your particular situation.

 

Updated 4/3/2020, 12:23 pm ET


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This material is for illustrative purposes and is not intended to constitute a contract. This material is presented for educational purposes only.

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