A Limited Extension for Insurance Enrollment: Precedents from Part D

By Jack Hoadley, Georgetown University Health Policy Institute

On March 25, the Administration created a grace period that will extend the March 31 Marketplace enrollment deadline for Americans who have run into roadblocks in their attempts to sign up for insurance coverage under the Affordable Care Act (ACA).  Various reporters and commenters have pointed to parallels with decisions made in 2006 around the first enrollment period for Medicare Part D.  Others reject the comparison, saying that the Bush Administration decisions on Part D were quite different.

Previously, we have reported on a number of the strategic decisions made by the Bush Administration “to delay or transition some key elements of the Part D program in response to technical and timing difficulties.”  Officials in 2005 and 2006 used demonstration program authority to make key adjustments when necessary.  One such step was to waive the late enrollment penalty for low-income Medicare beneficiaries who failed to sign up by the May 15 deadline.

We also reported on steps taken by the Bush Administration to address problems that arose when Medicare beneficiaries first started trying to use their new Part D benefit at pharmacies.  For example, many states stepped in and covered drug costs when dual eligibles were not correctly enrolled in Part D.  The Bush Administration later used administrative authority to repay the states.

Are these steps the same as those being taken to extend the enrollment deadline for coverage under the ACA?  Not exactly.  But what they share is a spirit of flexibility to make adjustments for the problems being experienced.

Part D had a longer initial enrollment period, through May 15, by statute.  Thus, despite facing technical problems in its roll-out, the program had more time for enrollment once many of the problems were fixed.  Plus, the technical demands on the Part D website and call center were substantially less than those that face the ACA Marketplaces.  An enrollment extension was not the primary issue in 2006.  Rather, in addition to the potential late enrollment penalties faced by some low-income beneficiaries noted above, beneficiaries were encountering problems filling their prescriptions.

In 2006, the Bush Administration used the authorities it had available to fix at least some of the problems that confronted the Part D program.  In 2014, the Obama Administration is taking the very same approach.  Today that means a grace period to allow more time for those Americans for whom website and call center difficulties blocked timely enrollment.  In both cases, the goal was to encourage people to enroll in programs created by Congress and to ensure that enrollees receive the benefits to which they are entitled.

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