July 13, 2020
We seem to be again encountering another layer of diffraction in our collective COVID-19 experience – we have been enjoying our increased freedom as each region in the country takes cautious steps to safely open up the economy and services while trying to prevent a severe second wave of COVID-19 cases in our communities and across Canada. Each time we adapt to our new environment, we are faced with a new challenge for which we need to understand, address, and accept. With the new wave of government / municipal by-laws to make requiring wearing masks mandatory in all public and enclosed indoor spaces, we find ourselves again pondering the implications – socially, psychologically, and economically.
The use of Personal Protective Equipment (PPE) has become a hot topic as it relates to group benefits plans as practitioners return to visiting patients in their offices. MFG has been documenting and researching this additional ‘cost of doing business’ and their cost implications to group benefit programs and employees.
Due to the pandemic, practitioners (dentist, chiropractors, physiotherapists) are required to use PPE while administering their services. The decision by these industries is to add the additional cost of PPE to service fees-various medical providers are faced with the same challenge and are working at ways to pass on these costs to their patients. MFG has confirmed with each group benefits insurance provider that these costs are not and will not be included in basic insurance contracts. Therefore, unless a Plan specifically provides this coverage, PPE costs will be borne by the end user, and we anticipate this new expense phenomena to be universal through all commercial services with costs somehow being passed to the consumer.
The first industry to formalize the fees for PPE is the dental industry. Dentists can charge for these fees either under the new Fee Guide codes which were added recently to manage the costs of PPE, or by increases the fees for their services rendered. If the dentist bills the fees under the new fee guide codes, reimbursement will be declined by the insurance provider and the individual will have to pay out-of-pocket. The average cost of the PPE will be approximately $25 per visit. If the dentist charges for the cost of PPE by increasing their service fees, the amount billed for the individual services could be (and would likely be) above the insurance providers “Reasonable and Customary” limit, which will also result in the difference being paid by the individual as an out-of-pocket expense.
Insurance providers are offering to add coverage for these services to benefit contract upon request, however there will be an increase to the benefit rate(s). If your group benefit plan includes a Health Care Spending Account (HCSA), the cost of PPE charges can be submitted as an eligible expense as long as the PPE qualifies as a medical device under the government of Canada’s definition.
PPE sold for medical purposes are classified as medical devices in Canada. Under the Medical Devices Regulations, medical masks, N95 respirators, medical gowns, face shields and medical goggles are Class I medical devices. Medical gloves are Class II medical devices. Specific criteria can be found at www.canada.ca/en/health-canada/services/drugs-health-products/covid19-industry/medical-devices/personal-protective-equipment/overview.html
MFG is here to answer questions about the implications of the costs of PPE to your benefits plan. If you would like to investigate the cost of adding PPE as a covered expense for your employees, let us know. If your employees have questions about their coverage of the reimbursement of a claim – for PPE or other issues, we are here to advocate for you and them.
We are here to help – The MFG Team