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5 min read

Families First Coronavirus Response Act & Update From BCC

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As daily news surrounding COVID-19/Coronavirus continues to put pressure on the entire world, we would like to give you the following updates on our service, process changes, and the impact of the situation. Be assured that the health and well-being of our employees, clients, participants, brokers, vendors, and business partners remain our utmost priority.


Client Service

BCC is making every effort to ensure that the presence of COVID-19 will not affect the great work we are doing for our clients. Our offices have reduced the number of on-site employees to lessen exposure and comply with social distancing. We have established remote working guidelines for each of our service lines of business to help ensure we meet expectations and deliver our best work to you every day. Rest assured that we have made all efforts to ensure that service is provided efficiently and effectively.



During these uncertain times, we have equipped our Renewal Teams to be fully operational remotely in order to ensure that all annual renewals continue on schedule through Zoom and teleconference sessions.


Processing Time

We are continuing to process all items as timely as possible. There is currently a 3-4-day delay in processing claim submissions (electronic and paper), with reimbursements the following suit. Please remind your employees that the most efficient way to submit claims is electronic via the My SmartCare online portal, mobile app, or e-mailing

  • There is currently a 3-day delay in processing COBRA paperwork (please note that we are still well within compliance of all Federal COBRA guidelines and timeframe requirements).

  • There is no delay expected in processing COBRA Initial Notices.

  • There is currently no delay to client invoicing, carrier payments, or individual COBRA/Retiree invoicing.


Impact of 'Families First Coronavirus Response Act' on Employee Benefits

The Families First Coronavirus Response Act (the “Act”) was passed by Congress and has been signed by the President. It requires most health plans to cover costs related to COVID-19 testing. In addition, it includes significant provisions that apply to private employers with fewer than 500 employees and public employers of any size. The Act requires these employers to provide up to 80 hours of paid sick leave for certain employees who are affected by the COVID-19 virus. It also expands FMLA protections, providing new partial paid leave to their employees who cannot work because they must stay home to care for children during school and daycare closures. Employers required to comply with the expanded leave and benefits will be eligible for a tax credit to help cover costs related to these requirements. Please contact your broker or legal advisor for more information on how this impacts your business.  


ACH Failure Policy

A change has been made to our policy regarding temporarily inactivating participants’ benefits debit cards 48 hours after a failed ACH. In an effort to mitigate potential risk, cards will now be inactivated immediately following a failed ACH. These failures typically occur due to the client having insufficient funds in their account or the client failing to authorize us to pull the funds timely. This policy change is effective immediately.


Dependent Care FSA

Can you allow your Dependent Care FSA participants to make election/contribution changes to correspond with changing daycare needs during the circumstances of COVID-19? The answer isn’t completely clear, but it seems allowable. One of the permitted Dependent Care FSA election change categories is, “Change in cost and coverage. Under these rules, certain changes in cost and coverage of the DCAP will justify a midyear change in the election. When there is a change in the cost of a dependent care provider, or when a participant changes dependent care providers, a plan usually can permit a midyear change in the election.”


Based on this rule, a change in DCAP elections mid-year due to a change in childcare providers and/or a change in the cost of care seems permissible. While it's not entirely clear that a daycare closing and the parent taking over childcare duties would fall under this category, it seems reasonable to assume it would in these circumstances. There is generally a bit of flexibility permitted with respect to DCAP election changes that isn't afforded to other types of election changes. It seems very unlikely that the IRS will take any significant enforcement action against employers who choose to allow the election changes while we are enduring this public health emergency.



To ensure that our broker, consultant, and carrier partners continue to receive the deserved attention to their prospective clients, BCC has fully equipped our Sales Teams to continue all efforts remotely via Zoom and teleconference sessions. This includes RFPs, RFIs, proposals, presentations, and system demos for all of our systems and services (including BenXcel, Employee Navigator, SmartCare, and ACAWorks).


Customer Service 

Our Customer Service Call Center remains available to your employees, Retirees, and COBRA beneficiaries with no change to service hours, but there may be a longer wait time than typically experienced:


BCC’s Enterprise Service Team remains available to you with no change to service hours, but there may be a delay in response time. Please e-mail


We value our relationship and we are committed to staying connected with you during this unprecedented situation. There will be more information shared on the status of operations as the situation continues to evolve.