This latest Bulletin supplements the provisions outlined Bulletins 2020-13, 2020-02, and 2020-04
The Commissioner of Insurance has issued a new Bulletin supplementing and expanding upon the previous Bulletins issued between March 26 and March 30, concerning the Coronavirus and the COVID-19 pandemic. The new Bulletin entitled, “Coverage for COVID-19 Treatment and Out-of-Network Emergency and Inpatient Reimbursement During the COVID-19 Health Crisis’, are directions to Commercial Health Insurers, Blue Cross Blue Shield of Massachusetts, Inc., and Health Maintenance Organization with regards to the DOI’s expectations regarding “Carriers appropriate coverage of treatment for COVID-19”.
Bulletin 2020-13; Coverage for COVID-19 Treatment and Out-of-Network Emergency and Inpatient Reimbursement During the COVID-19 Health Crisis; Issued 04/09/2020
In particular, the new Bulletin expands its guidance with respect to the measures for Treating Coronavirus; Coverage for Coronavirus Treatment in Acute Care Hospitals; Payment for Out*of-Network Emergency and Inpatient Treatment for Coronavirus, and Carriers Acting as Administrators.
Links to other Bulletins the DOI has issued on the COVID-19 public health crisis
The earlier Bulletins with their links are reprinted below and cover medical malpractice coverage, prescription drug access including prescriptions for chloroquine, and hydroxychloroquine, extending the special enrollment period for the uninsured to obtain health insurance on the Connector, limiting prior authorizations for Coronavirus testing in-network, and health carriers covering out-of-network testing if in-network is unavailable.
The following headlines are links to the full text of the bulletins. The statement under each link is from the preamble from the bulletin explaining its guidance, at least, in part.
Bulletin 2020-03; Special Open Enrollment Period Effective Immediately Until April 25; Issued 3/12/2020
The Bulletin 2020-03 entitled: “Special Enrollment Period Effective Immediately Until April 25:, which allows for a “limited time” special enrollment period in the Connector for qualified individuals who are currently without insurance. In particular, the Bulletin states in part:
“In light of the spread of COVID-19 in the Commonwealth and its impact to the public’s health the Connector has announced a limited-time special enrollment period (“SEP”) for qualified individuals who are currently without insurance. This Bulletin effectuates the commencement of an SEP during which currently uninsured Massachusetts residents can enroll in health coverage. This SEP will not allow currently enrolled individuals to switch plans – rather, it is strictly to allow for those without coverage to obtain insurance coverage.
The Connector has informed the Division that the Massachusetts special open enrollment period for eligible individuals will last through April 25, 2020…”
Bulletin 2020-04; Emergency Measures to Address and Stop the Spread of COVID-19 (Coronavirus); Issued 3/16/2020
Bulletin 2020-05; Flexibility in the Issuance and Administration of Insurance during COVID-19 (Coronavirus) Public Health Crisis; Issued 3/23/2020
The Bulletin lists measures indicated by the Division “to provide employers and individuals with as much flexibility as is reasonably possible during the period of the COVID-19 public health crisis to maintain their existing coverage, despite policyholders’ growing concerns about being able to send their premiums in on time.”
Bulletin 2020-06; Administration of Prescription Drug Benefits During COVID-19 (Coronavirus) Public Health Crisis; Issued 03/26/2020
Bulletin 2020-06 (3 pages) provides information to all Commercial Health Insurers, Blue Cross and Blue Shield of Massachusetts, Inc., and Health Maintenance Organizations about the Division’s expectations regarding steps Carriers are to take to help address concerns about protecting Massachusetts pharmacists and the public during the Coronavirus and COVID-19 public health crisis.
Note: Chloroquine and hydroxychloroquine. This bulletin addresses in one section, the Division’s awareness of concerns arising in the market about the prescribing of the two prescription drugs, chloroquine, and hydroxychloroquine, now in Coronavirus clinical trials, and sets out some guidelines for carriers about prescriptions for these drugs.
Bulletin 2020-07; Making Consumer Information Available During the COVID-19 Crisis; Issued 03/26/2020
Bulletin 2020-07 (2 pages) provides information to all Commercial Health Insurers, Blue Cross and Blue Shield of Massachusetts, Inc., and Health Maintenance Organizations (“Carriers”) about the Division’s expectations regarding steps Carriers are to take to educate consumers about how to use Carriers’ systems to obtain covered services for COVID-19 testing, diagnosis, and treatment, and how to process claims in the most efficient manner.
Bulletin 2020-08; Flexibility in the Issuance and Administration of Medical Malpractice Insurance during COVID-19 (Coronavirus) Public Health Crisis; Issued 03/27/2020
Bulletin 2020-08 (2 pages) provides information to all Medical Malpractice Carriers of every type operating in the Commonwealth about the Division’s expectations regarding steps they are to take to help address concerns about medical professional liability/medical malpractice coverage during the Coronavirus and COVID-19 public health crisis. The Division asks that all Medical Malpractice Carriers review their existing coverage and/or coverage forms to ensure that such coverage provides flexibility where needed and/or to file or add endorsements to their existing policies to ensure that existing coverage will apply to health care professionals who are acting within the scope of their professional license when they respond to the COVID-19 public health crisis, whether within Massachusetts or in another state.
Bulletin 2020-09; Special Open Enrollment Period Effective Immediately Until May 25; Issued 03/30/2020
Bulletin 2020-09 (1 page) advises that the Division in collaboration with the Commonwealth Health Insurance Connector Authority (the “Connector”) is announcing that the special enrollment period described in Bulletin 2020-03 for eligible individuals in the Commonwealth who are not currently enrolled in an insurance plan will have a special-enrollment period lasting until May 25, 2020.
Note: The special enrollment period under Bulletin 2020-03 lasts until April 25, 2020. Bulletin 2020-09 announces the extension of the special enrollment for any uninsured person for an additional month.
Bulletin 2020-10; Credentialing and Prior Authorization during COVID-19 (Coronavirus) Health Crisis; Issued 03/30/2020
Bulletin 2020-10 (4 pages) provides information to all Commercial Health Insurers, Blue Cross and Blue Shield of Massachusetts, Inc., and Health Maintenance Organizations (“Carriers”) about the Division’s expectations regarding steps Carriers are to take to help address concerns about obtaining medically necessary treatment during the COVID-19 (also known as Coronavirus) public health crisis.
Note: This bulletin also has a section advising about Prior Authorization Systems and COVID-19, with the statements about Coronavirus testing including:
- “If a patient is screened for symptoms either in a face-to-face or telehealth encounter and the patient’s symptoms are consistent with guidance put out by the Department of Public Health or the Centers for Disease Control and Prevention, Carriers are not to require prior approval for the patient being tested for COVID-19 by any practitioner within the Carrier’s network of providers.”
- “If an in-network provider is unable to be available for testing as needed, the Carrier is expected to pay for necessary testing when provided by an out-of-network provider.”
Recognizing that the COVID-19 crisis “may present challenges to Massachusetts licensed insurers and other regulated entities in meeting certain regulatory filing requirements” the Division of Insurance has issued guidelines and relief with respect to certain regulatory filing requirements during the current public health crisis. Those entities that may be affected by this new flexibility afforded by this Bulletin include Insurance Companies, Health Maintenance Organizations, Blue Cross and Blue Shield of Massachusetts, Inc., Fraternal Benefit Societies and Workers’ Compensation Self-Insurance groups.
Bulletin 2020-11; Flexibility for Compliance with Certain Filing Requirements in Light of COVID-19; Issued 04/03/2020
In particular, the Bulletin addresses various regulatory issues that may be affected by closures, particularly if personnel or other third-party service providers are unavailable to prepare and submit regulatory submissions:
- Notarization/Filing of Hard Copy Originals for Financial Statements
- Insurance Holding Company Filings
- Corporate Governance Annual Disclosures
- Audit/Internal Control Related Reports
- Insurer License Applications and Amendments
- Managed Care Accreditation Filing
- Mental Health Parity Annual Certification and Report
Bulletin 2020-12; Individual Insurance Licensing during the COVID-19 (Coronavirus) Health Crisis; Issued 04/03/2020
This Bulletin implements the Governor’s March 18th Order Extending the Registrations of Certain Licensed Professionals and aims to address concerns that continuing education providers, as well as those holders of an individual insurance license in the Commonwealth, may have with respect to licensing during the COVID-19 public health crisis. This includes insurance producers, public insurance adjusters, surplus lines brokers, reinsurance intermediaries, and life settlement brokers.
In particular, the Bulletin discusses the measures that should be taken with respect to three main licensing concerns: Extension of Insurance Licenses, Continuing Education, and Licensing Exams and aims to ensure that all individual insurance license holders can continue to provide their significant services within the Commonwealth without interruption.
Of particular note, are a couple of items highlighted from the Bulletin:
- Pursuant to the Licensing Order, all individual insurance licenses ‘in good standing’ as of the date of the Emergency Declaration that expire during the state of emergency are extended and shall remain valid for a period of 90 days following the termination of the state of emergency.
- Any approved classroom courses being offered online during the state of emergency do not have to be re-filed for approval.
- Anyone with an existing appointment at a Prometric testing center will be contacted by Prometric to reschedule to the exam. Rescheduled exams will not take place until after April 16