Highlights on the FFM Approach for 2016 Open Enrollment

Recent federal guidance about marketplace renewal notices reminds us that open enrollment is just four short months away: November 1, 2015 through January 31, 2016. Similar to the process last year, the federally facilitated marketplace (FFM) will automatically enroll eligible consumers into coverage if they don’t take any action before December 15, 2015 so that their coverage begins January 1, 2016 and is continuous. Enrollees can also go back to the marketplace to update their information, shop and compare plans, or select the same plan. And like last year, consumers that the FFM automatically re-enrolls have the opportunity to change plans or update their information until the end of open enrollment. However, if they do so after coverage begins on January 1, 2016, they may have to restart their deductibles. Consumers with catastrophic coverage and a hardship exemption won’t be automatically renewed – they must actively return to the marketplace to maintain their coverage.

The FFM has made some changes to the re-enrollment process this year, mostly relating to redeterminations for financial assistance eligibility. Unlike last year, the FFM will be providing redeterminations of financial assistance – advanced premium tax credits (APTCs) and cost-sharing reductions (CSRs) – for eligible enrollees that they automatically re-enroll. According to federal guidance, the FFM will use the latest income data available along with the price of the benchmark plan and federal poverty level guidelines for 2016 to do redeterminations alongside of automatic re-enrollment. This is different from last year, when the FFM did not provide a redetermination for financial assistance, but rather carried forward the same dollar amount of APTCs for the previous year. Only consumers who actively re-enrolled received a redetermination based on 2015 information like the updated price of the benchmark plan.

Also new this year is that the FFM will not provide any APTC and CSRs to those consumers who failed to file their 2014 tax return, as this is a requirement under the rules for APTC eligibility. The FFM will re-enroll these consumers into coverage, but without any financial assistance. The administration is currently working on a communications and outreach strategy for consumers who fall into this group.

Open enrollment and renewal notices will also be similar to last year’s, except that the FFM will not send an open enrollment notice to individuals who completed an application, but did not ultimately enroll into marketplace coverage. Consumers will receive an open enrollment notice from the marketplace and insurer with the following information:

Marketplace 2016 Notice:

  • a description about the redetermination and re-enrollment process
  • a reminder to report changes affecting eligibility
  • the open enrollment dates and the December 15, 2015 date as the last date for coverage starting January 1, 2016
  • a description of the redetermination process for financial assistance if automatically re-enrolled

Insurer 2016 Notice

  • the plan in which the consumer will be automatically reenrolled including a statement that consumers will be automatically reenrolled into the same or similar insurer’s plan if the plan is unavailable by December 15, 2015 if the consumer does not actively select a plan for 2016 coverage
  • key changes to benefits and cost-sharing between the 2015 and 2016 plans
  • information about the APTC

Insurers may not receive the APTC amount for 2016 from the FFM in time to include in their enrollee notices, meaning that enrollees may not know their net premium for 2016 until they receive their first invoice. The FFM is allowing insurers to use the 2015 APTC amount as long as they clearly indicate that the amount is an estimate only. In addition, insurers must inform consumers in the notice that the actual APTC amount will be provided on the bill for January 2016 coverage and/or a supplemental notice.

The FFM approach this year – in which eligibility redeterminations are based on the upcoming year’s health plan information is more aligned with the approach that many state-based marketplaces (SBMs) took last year. How some SBMs are approaching redeterminations and renewals for 2016 will be discussed in a forthcoming issue brief – so stay tuned.

 

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