FAQs for Employers and Producers – Self-funded groups

Updated November 10, 2021

We recognize the challenges COVID-19 and the associated state and federal guidance on businesses poses to you, your employees, and your business. Our top priority is supporting employees’ access to vaccines, connecting them to care and supporting you, our valued business partners, during this evolving crisis.

The following information is a compilation of the most frequent questions we have received to date. We have attempted to provide responses that apply in the broadest sense. As always, your account executive is available to answer questions specific to your plan. If you have stop-loss coverage, please check with your carrier for direction as well.

Any benefits changes you make should be reflected in your Summary Plan Description (SPD). Please contact your Regence account executive to modify your Regence-produced SPD.

Frequently asked questions

Member support FAQ
 What steps have we taken to support our members?

The health of our members is our top priority. Read the latest actions we’re taking to support our members.

  • No-cost COVID-19 vaccinations, including booster shots for those in certain high-risk populations who are authorized by the CDC to receive them. The federal government is paying for enough vaccine doses to immunize every American during the course of the pandemic. Administrative fees will be covered by health plans, including self-funded plans. Legacy and retiree only plans are not required to cover administration without cost-sharing.

  • No-cost COVID-19 diagnostic (antigen and molecular) and antibody testing when ordered by a member’s attending provider as part of appropriate medical care. This includes high-deductible health plans with HSAs. Tests must be performed at a CLIA-certified lab (including drive-up testing sites), or the test manufacturer must have FDA Emergency Use Authorization (including at-home kits).

  • As with drug testing for employment, insurance does not cover testing for employment, surveillance, or extracurricular activities, such as travel, school, sports or summer camps.

  • Groups may opt-in to have no cost shares (deductibles, copayments and coinsurance) for members’ COVID-19 treatments at in-network providers.

  • Extending any expiring prior authorizations for elective services when requested, by up to three months, or through 12/31/21, whichever is latest.

Enhanced support for high-risk members

  • We’re in contact with high-risk members using our case management services to ensure they have the support they need.

  • As we learn of members hospitalized with the virus, we are reaching out to provide personalized support.

  • We’re moving members on infused medications from hospital to home settings or infusion centers.

Access to needed medications

  • Members may receive early refills of most medications through the end of the declaration of emergency in the state where their plan is issued.

  • Members can request a 90-day refill of medications for chronic conditions such as heart disease, asthma, diabetes and others. Some drugs are not eligible for extended day supply, including controlled substances and certain specialty drugs (ineligible drugs are those in the “Narcotics” section or marked “SP” on our drug lists).

  • Members with prescription coverage through Regence can order home-delivery prescriptions through the AllianceRx Walgreens Prime website.

Enhancing coverage for virtual care

To help slow the spread of infection and ease pressure on doctor’s offices and emergency rooms, we’ve enhanced coverage for virtual care:

  • Some members, upon groups’ opt-in, have access to telehealth vendors that provide services such as video visits and secure messaging with doctors and nurses, and home health visits in select areas. These options may differ by employer, and employers can consult their summary of benefits coverage (SBC) for their specific telehealth offering. Groups that don’t have embedded telehealth are encouraged to contact their Account Executive for information on available options and instructions for opting-in.

  • Employees should sign-in or create an account on regence.com, or download the Regence app, to learn about the virtual care options included in their plan. A flyer and video on regence.com contain all the instructions for doing this; be sure all employees have access to these instructions.

  • We’ve expanded the range of services that can be delivered by providers using virtual care options.

  • Self-funded groups may also waive the member deductible for telehealth vendor services and virtual care services.

Expanding resources for self care

To help members address a wide range of emotional and physical health needs, we’ve broadened access to three useful tools:

  • Active&Fit – members have free access to 200 on-demand digital workout videos and daily live workouts from Active&Fit. Enrollment in Active&Fit is not required; Regence members need only to access the Active&Fit website from their Regence account page and register there to receive access to the workout videos.

  • Regence Empower™ – provides members tips for staying healthy, what to do when sick, and advice to help slow the spread of the disease. Includes self-guided programs for managing stress, enhancing physical activity, and building resilience, along with personal challenges supporting sleep, nutrition, physical activity, and social and emotional well-being.

  • Symptom Checker – offers members timely guidance and support to help them determine whether medical attention is needed. Not intended to replace a clinical assessment or the judgment of health care professionals.
Eligibility FAQ
 How is eligibility defined for employees on self-insured plans?

We follow the self-insured plan sponsor’s definition of an eligible employee and guidance on plan administration for the following scenarios:

  • Keeping furloughed employees covered under the health plan

  • Waiving waiting period for employees returning to the plan after a lay-off, furlough or termination

  • Adjusting required hours for plan eligibility
Plan & benefits FAQ
 Can we maintain our self-funded plan if we’re required to temporarily close?

Yes, as long as there is active enrollment on the plan. If all employees are terminated from a plan, the contract will cancel and will need to be reinitiated. Minimum enrollment for self-funded groups is 51 employees. For groups returning with fewer than 51 employees, fully insured plan designs are available.

 Can we have a special COVID-19 open enrollment period to allow employees who waived earlier on the plan to enroll?

Yes. We follow the plan sponsor’s definition of open enrollment and special enrollment periods. Some state-based exchanges are offering special enrollment period for individual participants.

 Can we change or modify our plans midyear?

Yes. Self-insured plan sponsors can modify benefits and allow for an election or downgrade to enrollment midyear.

 If we offer multiple plans, can we allow our employees to downgrade benefits midyear?

Self-insured groups may elect to allow members to change at their discretion.

 Will Regence modify rates for changes in enrollment greater than 10 percent?

Enrollment changes as a direct result to COVID-19 will not be subject to rerate.

 How is Regence administering coverage for COVID-19 vaccinations, testing and treatment?

We are applying no member cost share to COVID-19 vaccinations, and antigen and molecular diagnostic testing and the associated office visit as prescribed by federal mandate. This includes high deductible health plans. Testing must be ordered by a physician. We also cover COVID-19 antibody tests at no member cost share when ordered by a member’s attending physician and part of appropriate medical care. Tests must be performed at a CLIA-certified lab, or the test manufacturer must have FDA Emergency Use Authorization. As with other tests for employment, such as drug tests, antibody tests for employment purposes are not covered by insurance.

Self-insured customers may opt-in to non-federally mandated benefits for COVID-19 including treatment at no cost to employees or family members.

 Does Regence have the ability to report COVID-19 claims separately?

Yes. Using TrendSmart, our reporting and analytics tool, plan sponsors can request CPT-specific reports, including those for COVID-19.

 What behavioral health options are available to our employees?

Your health plan may include an Employee Assistance Plan (EAP) benefit. Telehealth vendors also provide behavioral health services. In addition, under the optional virtual care expansion, members’ regular providers may be able to offer telehealth services.

 Can we add a telehealth vendor to our plan?

Yes, you can add Doctor on Demand. Call your account executive to learn more. Self-funded groups may also opt in to the expansion of services that can be provided through virtual care options. Many of our contracted network providers offer telehealth services for primary care visits, behavioral health, and more. These visits are covered with the same cost sharing provisions of your plan, as an office visit. This is separate from the existing telehealth benefit in some contracts that provide for limited telehealth services and provider reimbursement at the telehealth rate.

 What does the optional expanded telehealth policy cover?

To help prevent the spread of infection and ease pressure on doctor’s offices, urgent care centers and emergency rooms, we have temporarily expanded the services available through our virtual care benefit for our fully insured and Medicare customers. Self-funded groups may opt-in to this expansion. Under the expansion, any contracted provider may now offer virtual care services, even on a non-HIPAA-compliant platform. This includes routine preventive appointments with members’ primary care doctors and behavioral health providers. This expansion will remain in effect through each state’s emergency declaration. The member’s coinsurance and deductible will apply to these services, however self-funded groups may opt to waive deductibles for telehealth and virtual care services.

 How is Regence complying with the DOL guidance on COBRA deadlines?

This rule applies to ERISA groups only. COBRA remains an employer-specific responsibility. The following represents our understanding at this point in time.

The DOL, IRS and HHS guidance under the EBSA Disaster Relief Notice 2020-01 extends certain COBRA timeframes and deadlines for participants to consider coverage elections and benefits decisions.

Specifically, Final Rule provides plan participants, beneficiaries, qualified beneficiaries, and claimants with relief from meeting the below referenced periods and dates during the period of March 1, 2020 until 60 days after the announced end of the COVID-19 national public health emergency (or such other date announced by the Agencies in a future notice):

  • The 30-day period (or 60-day period, if applicable) to request a special enrollment;
  • The 60-day election period for COBRA continuation coverage;
  • The date/deadline for making COBRA premium payments;
  • The deadline for individuals to notify the plan of a qualifying event or determination of disability;
  • The deadline within which employees can file a benefit claim, or a claimant can appeal an adverse benefit determination, under a group health plan’s or disability plan’s claims procedures.
Vaccines FAQ
 Which COVID-19 vaccines are covered?

All vaccines that have received approval or emergency use authorization from the U.S. Food and Drug Administration (FDA) for public distribution are covered. These include the Pfizer-BioNTech (now called Comirnaty), Moderna and Johnson & Johnson vaccines. The federal government is paying for enough vaccine for every American to be vaccinated during the course of the pandemic.

Vaccine administration is covered at no out-of-pocket cost for Medicare, fully insured and most ASO members. Legacy and retiree only plans are not required to cover administration without cost-sharing. However, we have chosen to cover the administrative fee for fully insured legacy plans without cost-sharing.

Balance billing is not permitted. From the Centers for Disease Control and Prevention (CDC): “Providers that participate in the CDC COVID-19 Vaccination Program contractually agree to administer a COVID-19 vaccine regardless of an individual’s ability to pay and regardless of their coverage status, and also may not seek any reimbursement, including through balance billing, from a vaccine recipient.”

 When can members get a COVID-19 vaccine?

COVID-19 vaccines are available to all members age 5 and older.

The FDA has approved the two-dose Pfizer-BioNTech vaccine (now called Comirnaty) for people age 16 and older, and Emergency Use Authorization (EUA) for people age 5-15. In addition, the FDA has approved EUA for the one-dose Janssen (Johnson & Johnson) and two-dose Moderna vaccines for people age 18 and older.

People who receive the two-dose Comirnaty and Moderna vaccines should have their two doses administered three weeks apart.

 When can members get COVID-19 booster shots?

The CDC has authorized COVID-19 booster shots for the following high-risk populations:

  • individuals 65 years of age and older;
  • individuals 18 through 64 years of age at high risk of severe COVID-19; and
  • individuals 18 through 64 years of age whose frequent institutional or occupational exposure to SARS-CoV-2 puts them at high risk of serious complications of COVID-19 including severe COVID-19.

COVID-19 booster shots are authorized for people in the high-risk populations listed above as follows:

  • At least six months after receiving their primary two doses of the Comirnaty or Moderna vaccines
  • At least two months after receiving their primary dose of the Janssen (Johnson & Johnson) vaccine
 Where can members get a COVID-19 vaccine?

COVID-19 vaccines are widely available through healthcare providers and pharmacies everywhere in the U.S. Employers with Regence health plans can host an onsite vaccination clinic, providing COVID-19, influenza, tetanus, hepatitis and other routine vaccinations with no out-of-pocket costs to employees and covered dependents. Click on your state name below for more information about employer onsite vaccination clinics.

Each state’s health department will have specific information about vaccine prioritization and distribution.

 What are we doing to support COVID-19 vaccinations in the community?

We are working to encourage all members to work with their medical provider to get vaccinated. Regence is working with our community partners, public officials and others to ensure that underserved communities and people of color – groups that have been disproportionally affected by the pandemic – are vaccinated.

 Where can people go for more information?

Members should check their state’s health department website or call their doctor or pharmacist to schedule an appointment to receive the vaccine.

The CDC provides these resources to learn more about the COVID-19 vaccine:


 Who pays for the vaccine?

The vaccine itself doesn’t cost consumers anything regardless of insurance coverage. The federal government has bought enough vaccine doses to immunize every American. The Centers for Medicare and Medicaid Services (CMS) or private insurance pays for the administration of the vaccine. Older legacy plans may pass administration costs on to their members.

 What is the anticipated impact of COVID-19 on health plan premiums?

It is too early to tell if COVID-19 will have an impact on future premiums.

 What is the difference in cost between the COVID-19 vaccines vs. the flu shot?

The administrative fee for the flu vaccine is around $7 versus the fee for administering the COVID-19 vaccine, which is currently around $45. In addition to the administrative fee, vaccine costs will vary based on manufacturer pricing. At present, all drug costs for COVID-19 vaccines are being covered by the government.

 What is the status on vaccine options, including efficacy rates and FDA approval of each (including those in the pipeline)?

We follow the New York Times vaccine tracker for the latest on vaccines and suggest you do too.

  How do we determine eligibility and the timeline for vaccination scheduling?

For the most accurate and up-to-date information on vaccine eligibility, prioritization and distribution, the best source is your state’s public health department website:

 What steps do we need to take to ensure that everyone understands the importance of being vaccinated?

Lead by example. Everyone can contribute to community health by:

  • Getting vaccinated.
  • Practicing the three Ws: wear a mask when in public, wash hands frequently, watch your distance from those outside your household.
  • Quarantining at the first sign of possible infection symptoms or when exposed to someone who is known to be infected.
  • Stopping the spread of misinformation. Check your information sources before sharing information about the pandemic with anyone. When in doubt, rely on your state health department, the FDA or the CDC.

Safety & Efficacy

 What is the length of efficacy for the various COVID-19 vaccines?

There is evidence that vaccine efficacy begins to wane after several months, and medical experts are learning more about vaccine efficacy as more time passes since the first eligible recipients were vaccinated in late 2020 and early 2021. Top medical and public health experts and the U.S. Department of Health and Human Services recently issued guidance for all American adults that received the Moderna or Pfizer-BioNTech (Comirnaty) mRNA vaccine to receive a third dose eight months after their second dose, pending FDA approval; however, at this time, only a third booster dose of Comirnity has been approved by the FDA, and only for the following high-risk populations:

  • Individuals 65 years of age and older
  • Individuals 18 through 64 years of age at high risk of severe COVID-19; and
  • Individuals 18 through 64 years of age whose frequent institutional or occupational exposure to SARS-CoV-2 puts them at high risk of serious complications of COVID-19 including severe COVID-19.

Research is still being done to determine whether boosters will be authorized for recipients of the one-shot Johnson & Johnson vaccine. People are still considered fully vaccinated after receiving their single dose of J&J or their second dose of the Moderna or Comirnaty vaccines.

The CDC will be your best source of information about vaccines for COVID-19.

 Do we have a choice of vaccine, and which is best?

Medical experts advise getting whichever vaccine is available to you. They all protect against serious illness and death.

 Is it a live vaccine? Does it provide immunity, or just protect against severity?

The current vaccines do not contain the coronavirus or inactivated virus. NPR offers a great explanation on what vaccine efficacy means. Getting vaccinated can dramatically reduce the chance of you getting COVID-19. If you still get infected and have symptoms, the vaccine can protect you against serious illness. Currently with people who’ve been vaccinated and still contracted COVID-19, the death rate is zero and one person was hospitalized.

 How can we trust the clinical trials – were they done for long enough?

Vaccines are developed by teams of world-class scientists with many years of education and experience. All vaccines undergo extensive trials to prove safety and effectiveness, involving tens of thousands of people who volunteer to receive the vaccine. The FDA grants emergency use authorization (EUA) only when independent analyses confirm a vaccine is safe and effective. Full approval is granted when, over time, the FDA has amassed even more scientific evidence to support use of the COVID-19 vaccines, showing that the benefits of the vaccine are greater than its risks, and that the vaccines can be manufactured reliably, safely and with consistent quality.

The Pfizer-BioNTech (Comirnaty) and Moderna vaccines have an effectiveness rate of more than 95% in adults. While these vaccines were developed in 2020, the technology behind them has been studied for years. The vaccines do not contain the virus or inactivated virus. You cannot get COVID-19 from the COVID-19 vaccines.

Comirnaty has received full FDA approval for people 16 years of age or older, and EUA for people 5 to 15 years of age; and as a booster for certain high-risk populations. COVID-19 vaccines manufactured by Johnson & Johnson (also known as Janssen Biotech, a pharmaceutical company of J&J) and Moderna vaccines have received EUA for people 18 years of age or older.

We recommend reviewing the New York Times vaccine tracker for a plain language explanation of how vaccines are developed and what phase COVID-19 vaccines are currently in.

 Regarding the Pfizer-BioNTech (Comirnaty) and Moderna vaccines; does your second dose have to be the same type as the first?

We recommend following CDC recommendations: "The safety and efficacy of a mixed-product series have not been evaluated. Both doses of the series should be completed with the same product."

The CDC has authorized the mixing of different COVID-19 vaccines for boosters for people in high-risk populations.

 Are the current vaccines effective against the new strains? Are they being tested and/or modified to respond?

Yes. The current vaccines help protect against moderate to severe illness and death. The emergence and transmission of new virus strains is highly dynamic, and we suggest referring to the CDC for the most current information.

 What are the short-term side effects of the vaccines?

The majority of people will experience no side effects other than a sore arm. About 10% may have flu like symptoms for a couple of days as the body develops antibodies. This is normal and generally not cause for alarm. Providers typically require vaccine recipients to wait for a 15 to 30-minute observation period just to be safe.

 What are the long-term side effects of the vaccines?

The CDC says that serious side effects that could cause a long-term health problem are extremely unlikely following any vaccination, including COVID-19 vaccination. The CDC offers comprehensive information about vaccine safety and monitoring.

 Once a person is vaccinated, can they still transmit the virus?

Yes. Fully vaccinated people can still contract the coronavirus that causes COVID-19, and spread it to other vaccinated and unvaccinated people. As with the unvaccinated, a vaccinated person can contract the coronavirus and experience a range of symptoms. In rare cases, a vaccinated person who contracts COVID-19 can experience moderate to severe symptoms requiring hospitalization.

Even after receiving a vaccination, safety protocols including masking, distancing, washing hands frequently, and quarantining if symptoms or exposure to a known infected person occur are all strongly recommended to help prevent the spread of COVID.

 Do the vaccines change your DNA? Or cause a gene mutation in humans?


 Is J&J also an mRNA vaccine?

No. J & J is not a mRNA vaccine but a vector-based vaccine using a modified adenovirus using a double stranded DNA to cause the host cell to produce mRNA and spike proteins resulting in an immune response (antibodies) ready to attack a COVID-19 virus. For more information, read: How the Johnson & Johnson Covid-19 Vaccine Works - The New York Times (nytimes.com)

 Is it true that there are nanoparticles contained within these injectable technologies?

Yes. The Novavax is an example of such a vaccine technology. How the Novavax Covid-19 Vaccine Works - The New York Times (nytimes.com)

 Is there anyone who shouldn’t get the vaccine?

Some immunocompromised individuals should not get a COVID-19 vaccination. Please consult with your doctor if you have any questions about getting vaccinated, whether related to allergies, pregnancy, or other medical or health conditions.

 What alternatives are available outside of taking these vaccines?

Medical evidence shows that getting a COVID-19 vaccination can help keep you, your family, your community, and your country healthy and safe. Getting vaccinated can greatly reduce your chances of experiencing moderate to severe illness and death should you contract the coronavirus.

Available COVID-19 vaccines have undergone rigorous clinical trials to prove safety and effectiveness before they receive permission from the FDA for broad distribution. Clinical trials involve tens of thousands of people who volunteer to receive the vaccine. The FDA grants emergency use authorization only if independent analysis confirms the vaccines are safe and effective.

 What about the use of Ivermectin?

Regence health plans cover FDA-approved treatment for COVID-19. Ivermectin is not approved for the prevention or treatment of COVID-19. There is no clinical evidence supporting the efficacy of Ivermectin for treatment of COVID-19 symptoms.

After the vaccination

 Is it still necessary to wear a mask after receiving the vaccine?

Yes, the CDC has issued guidance recommending continued mask wearing, physical distancing and frequent handwashing when in public places. Many states have reinstituted public mask wearing mandates since the most recent COVID-19 surge, fueled by the Delta variant, began. In addition, quarantining immediately when symptoms or exposure to an infected person occur is also strongly recommended.

It takes a few weeks for your body to build up immunity after vaccination. In addition, while the vaccines have a high efficacy rate for preventing serious illness and death, a vaccinated person may still be susceptible to getting the virus and transmitting it to others.

Check with your state or local health department on additional safety protocols for your community.

 How long will it be before there’s no more need for masks and social distancing?

That really depends on us. If we continue to mask up, maintain physical distance, wash hands frequently, and quarantine at the first occurrence of symptoms or exposure to a known infected person, we can help stop the virus from spreading. Your state and local health departments will be your best source of information about community safety protocol.

 What are the metrics and anticipated timeline for herd immunity from COVID-19?

Medical experts do not know for sure. Herd immunity occurs when the vast majority of a population is immune from an infection. For highly infectious viruses such as measles, herd immunity occurs when 92 – 94% of the population is immune. At 70 – 80% herd immunity, we would start to see a reduction in case rates. The CDC will be your best source of information about herd immunity for COVID-19.

 I’ve heard that people that have survived COVID-19 feel they have protection and may not need a vaccine. Can you address this?

It is unknown how long natural immunity lasts. Reinfection with COVID-19 is common, and often with more severe symptoms than the initial infection. If it’s been more than 90 days since you’ve had COVID-19, medical experts recommend getting vaccinated.


 Are there any opportunities for onsite vaccination clinics? (like with the flu shot)

Yes. Employers can begin scheduling onsite vaccination clinics. Many onsite vaccination clinic providers offer COVID-19 and flu shots. And, to help employees catch up on other routine annual vaccinations, many providers also offer shots for hepatitis, pneumonia, shingles, tetanus, and more. Employers should contact their Regence account representative for more information about how to schedule an onsite vaccination clinic.

 Can employees be required to be vaccinated before returning to onsite work? And require proof of vaccination?

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) is finalizing a COVID-19 Vaccine and Testing Emergency Temporary Standard (ETS) requiring that all employers with 100 or more employees ensure their workforce is fully vaccinated. Unvaccinated workers will be required to produce a negative COVID-19 test result on at least a weekly basis before coming to work. You can learn more about the COVID-19 Vaccine and Testing ETS here.

 Is COVID-19 testing for the purposes of employment covered by insurance?

No. COVID-19 testing is only covered by insurance when ordered by a member's provider as part of appropriate medical care. Included are tests obtained in: FDA emergency use authorized facilities and drive-up testing sites; CLIA-certified labs; and FDA-authorized at-home test kits. Testing for the purposes of employment is not covered by insurance, and employers are not required to pay for testing of employees.

 How can we encourage or incentivize our employees to get the vaccine?

Please consult your legal counsel.


The recording of the full webinar is available for playback and future reference here. If you need ongoing updates related to COVID-19 and our efforts to support you at this time, please contact your account manager.

Additional Resources:

Centers for Disease Control and Prevention (CDC)
World Health Organization (WHO)
New York Times vaccine tracker
Oregon Health Authority
Washington Department of Health
Utah Department of Health
Idaho Department of Health