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The impact of COVID-19 is changing the way we all do business and we recognize that you have questions about your group benefits program. As an essential service, we want to assure you that even in these uncertain times we’re here for you. We remain open for business and committed to providing you with the expert advice and guidance you’ve come to expect from Cowan. We’re all in this together, and we are working to help protect you and your employees.
If we have a layoff, what happens to our employees’ benefit plan eligibility?
Your contract may already have provisions detailing which benefits and how long they will be continued when employees are on layoff. If your contract doesn’t contain specific language on the continuation of coverage, contact your Cowan consultant for assistance because this varies by carrier.
Most carriers will provide an extension of coverage that satisfy legislative requirements. Providing extensions of coverage greater than what is required by law will require the approval of your carrier.
When we recall employees from a layoff, how quickly can their coverage be re-instated?
Depending on how long they have been without coverage, the waiting period, if your plan has one, may not be in effect.
You could also ask the carrier to waive the waiting period if it is applicable due to the gap in time from loss of coverage to reinstatement. Contact your Cowan consultant for assistance with this.
How much time do employees have to submit claims after losing coverage?
The best practice is to have the claims submitted a quickly as possible. Depending on the time of the year, your contract with the carrier may have a requirement to submit claims within a certain amount of months following the end of the year.
Can employees continue their coverage on their own with our carrier if they are terminated?
Employees cannot continue the benefit plan coverage own their own with your carrier.
They can convert their life insurance without proof of insurability with your carrier if done so within 30 days of loss of coverage through your benefit plan.
Employees could also purchase individual health and dental coverage that may not require proof of insurability if done so within 30 days of losing their coverage under your benefit plan.
Can we have the employees pay the premium for our benefit plan?
Yes, however, at least 50% of the total premium must be paid by the employer. The employer is responsible for remitting 100% of the premium to the carrier.
What happens if we are late paying our benefit plan premiums?
Your contract may have details on what happens if you are late paying the premium. Typically, premiums are due the first of the month. However, in many situations, nothing happens until the premium has been outstanding for 30 days or longer. After this time claims payments and the coverage could be suspended pending payment of the outstanding premium.
Your carrier may have implemented an extended grace period for premium payments. Contact your Cowan consultant for more information.
Can I put our plan in “suspension?”
The ability to do this depending on your carrier. Contact your Cowan consultant for assistance.
If I have a renewal coming up in the next few months, will it be delayed?
There is no insurance carrier standard on this at this time. To date, a number of carriers have shared their process with us, but it depends on the number of employees covered.
We are proceeding with the expectation that upcoming renewals will continue as scheduled. If you have specific concerns on your upcoming renewal, contact your Cowan consultant.
Can I continue to make amendments to my plan?
Some carriers have put a moratorium in place for future Short-term Disability plan amendments. Amendments that have already been communicated to the carrier for a future date may continue as scheduled. Connect with your Cowan consultant for more information.
Amending other parts of the benefit plan you might be considering may proceed. Note that employees must be actively at work on the date of the change for the change to be in force for them.
Can I continue coverage if we reduce our hours of work?
Your contract will detail the minimum hours of work per week for coverage to be in place. Any changes in the minimum number of hours of work per week for eligibility must be on a class basis. It cannot be applied on an employee by employee basis.
Many of the carriers have put a position on this that might vary from what is in your contract. Connect with your Cowan consultant to learn how this might apply to you.
What happens to the benefit coverage if we temporarily reduce pay?
The income-related coverage, like life insurance, LTD, and STD, will be based on the reported income to the carrier.
Reductions in pay should be reported to the carrier in the same manner any change in income has been. However, many carriers are allowing to maintain income-related benefits to remain at the prior levels. Connect with your Cowan consultant to discuss how you want to have this put in place.
I have a flexible benefits plan that allows employees to change coverage for life event changes, how does what we are going through today apply?
The specifics within your flexible benefits plan on life event changes are not impacted by the COVID-19 situation.
How has Out of Country Medical Emergency coverage been impacted by COVID-19?
Many carriers have extended the trip duration for employees already out of the country and trying to return to Canada. Speak with your Cowan consultant to understand what your carrier has done.
For employees who are out of the country for essential travel (e.g. commercial truck drivers), the coverage remains in force.
For all other out of country medical emergency coverage questions, contact your Cowan consultant.
For our TPA Clients
Can I still submit my claim?
Members and providers can continue to submit their Group Benefits health and dental claims through our Member Portal or by mail or fax at 613-747-7771.
How will I receive payment for my claim?
Members who are signed up for Electronic Fund Transfer (EFT) have eligible claims deposited directly into their bank account instead of receiving a cheque. Register for EFT through the Member Portal or contact us at firstname.lastname@example.org or 1-888-509-7797.
Where can I call for help submitting a claim or to ask questions?
Members, providers, and plan sponsors can contact us at email@example.com or call 1-888-509-7797.
Where can I find my insurance card?
An online version of your e-Card can be accessed via through the Member Portal which you can show to a provider for the plan number details on your phone or print a paper copy.
How can I remit my monthly premium?
Premiums can be remitted using online banking. Find out how by contacting us at firstname.lastname@example.org or by calling us at 1-888-509-7797
During this uncertain time, can we suspend contributions to our registered pension plan?
As of May 5, 2020, the Minister of National Revenue will waive the minimum 1% employer contribution rule for the remainder of 2020 if the plan is amended to reflect this.
This measure only applies for the remainder of 2020 for plans that submit an amendment to the Registered Plans Directorate and the applicable provincial jurisdiction.
If we elect to reduce the contributions to our registered pension plan, do we have to amend our registered pension plan and provide the members with notice?
Yes, the plan would require an amendment. As a reduction in contribution rate is viewed as an adverse amendment, notification to members is required. In some jurisdictions, notice must be provided to members prior to the amendment taking effect.
Has there been an extension to the period of time we have to remit contributions?
No, our carriers have confirmed that all contributions must be remitted as usual in accordance with the plan terms and the legislation. Generally, contributions must be remitted within 30 days of being deducted from an employee’s pay for employee contributions and for contributions the employer is required to make.
If my employee is on emergency leave due to COVID-19, do I have to continue contributions to the registered pension plan even though I am not paying the employee?
The requirement to continue to contribute for such leaves is addressed in the Employment Standards Act. Keep in mind that employment standards legislation provides the minimums that must be adhered to. Employers should be reviewing their internal policy regarding leaves, collective agreements, employment contracts etc. to determine if contributions are required for such periods.
|Province||Contributory Plan (ie: plan where the employee must make a contribution)||Non-Contributory Plan (ie: plan where the employer makes a contribution that is not dependent on an employee contribution)|
|British Columbia||Yes, if the employee continues to contribute||Yes|
|Alberta||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Saskatchewan||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Manitoba||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Ontario||Yes, if the employee continues to contribute||Yes|
|Quebec||Yes, if the employee continues to contribute||Yes|
|New Brunswick||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Prince Edward Island||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Nova Scotia||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Newfoundland and Labrador||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
|Federal||No employer contributions are required even if the employee continues contributions||No employer contributions are required|
Our company has temporarily ceased some or all of our operations due to COVID-19 and will no longer be remitting contributions to our pension plan for impacted employees, should we terminate those laid off members from the plan?
As no pension contributions are due to be paid for impacted employees given the temporary closure of business and employees have been temporarily laid off, members should not be terminated from the plan at this point. Once the company reopens or employees are recalled, pension contributions will resume. In any provinces that require expected contributions forms (e.g. Ontario – Form 7), the Pension Plan Administrator will need to submit updated forms.
Is the government offering extensions on filing requirements?
This will vary by jurisdiction but, for Ontario registered pension plans, the Financial Services Regulatory Authority (FSRA) has confirmed that Pension Plan Administrators may request automated deadline extensions of up to 60 days in the FSRA Pension Services Portal. This applies to Annual Information Returns and Financial Statements (including audited statements).
If an extension of more than 60 days is needed, Plan Administrators should contact the assigned Pension Officer directly, preferably by email.
Your Cowan Consultant can help you request an extension, determine who your Pension Officer is, and email them on your behalf if required.
For federally regulated plans registered with OSFI, deadlines have automatically been extended and there is no need to apply for an extension. The following filings that are normally due six months after plan year-end are now due nine months after plan year-end: Annual Information Return, Certified Financial Statement and Auditor’s Report Filing Confirmation. In addition, deadlines for annual statements to members and former members and spouses or common-law partners are also delayed to nine months after plan year-end, however, administrators should notify recipients of the delay.
Are Ontario Pension Assessment fees being waived?
No, fees are not waived, however, FSRA is deferring invoices for 2020-21 until further notice.
What if an employee does not access to a printer or scanner to complete paper enrollment forms, beneficiary changes etc.?
Reach out to your Cowan Consultant to discuss options that may be available to your plan members.
Our company sponsors a Group RRSP to which we also contribute. Can we temporarily stop contributions?
Contributions made by employees via payroll deduction and any contribution the employer decides to make is part of the employment contract and a part of the employees’ overall compensation. Any changes to the terms of that contract would need to be decided between the employee and employer, and communicated to the carrier.
Our Group RRSP rules apply a suspension of employer contributions where an employee makes a withdrawal from the plan. Can we waive this rule temporarily?
The employer establishes the rules regarding the suspension of contributions, therefore if the employer agrees, the rule can be waived. This change should be communicated to the carrier.
Our Group RRSP plan doesn’t allow for withdrawals while employed. Can we waive this rule temporarily?
The employer establishes the rules regarding withdrawals while employed, therefore if the employer agrees, the rule can be waived. This change should be communicated to the carrier.
Can I reduce or stop contributing to my pension plan?
Reduction or cessation of member contributions is only permitted if allowed by the plan rules. Typically, if membership in the pension plan is voluntary, a member may suspend membership while employed. You should speak to your employer/plan administrator.
Can I withdraw my pension assets for financial hardship?
No, assets in a pension plan cannot be withdrawn due to financial hardship while you are active in the plan.
I was terminated from my job because my company closed temporarily due to COVID-19. Can I withdraw my pension assets?
At this time, the termination is viewed as a temporary layoff if it is related to COVID-19, therefore pension assets cannot be withdrawn.
How does the change to the Registered Retirement Income Fund (RRIF) minimum affect my future RRIF payments?
The pre-March 18, 2020 RRIF minimum amount has been paid out without withholding tax. At this time, unpaid minimum amounts can continue to be paid at the pre-March 18, 2020 level without withholding tax on the amount in excess of the “new minimum”. If you want post-March 18, 2020 payments based on the new minimum, you will need to request a reduction. Post-March 18, 2020 payments will NOT be automatically adjusted.
Note: these answers are not legal interpretations and you should seek a legal opinion where appropriate as well review your internal policies, collective agreements, employment contracts etc.
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Return to Work, Effective Workplace Strategies
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Return to Work, Wellness, Health Claims Trends, and Retirement – Impact of COVID‑19 on the next 12 months.
Presented in partnership with Miller Thomson LLP