On December 1 the Center for Consumer Information and Insurance Oversight (CCIIO) published guidance for insurers on the re-enrollment process for the federally facilitated health insurance marketplace (FFM). While the target audience is those running insurance company operations, the guidance contains some useful information for Navigators and others working to help consumers through the re-enrollment process. Below are a few highlights.
Notices for those who do not actively re-enroll
In addition to the notices that enrollees received on the eve of open enrollment, all enrollees for whom the marketplace is not able to process an automatic renewal will receive a “Marketplace Enrollment Confirmation Message” that they aren’t being re-enrolled. Because consumers won’t receive this notice until after Dec. 15th, the cutoff date for coverage to start January 1, 2015, they could have a gap in coverage unless they qualify for a special enrollment period (SEP). The message they get from the FFM will direct them to the Call Center to determine whether they’re eligible for a SEP. Those who qualify for a SEP may also be eligible for an accelerated or retroactive coverage effective date, depending on when they return to the marketplace to select a plan.
Note, however, that not everyone who misses the December 15th cutoff will qualify for a SEP. If their failure to enroll was caused by “error, misrepresentation or inaction” by the marketplace, or a marketplace assister or agent, then they may qualify for a SEP.
For people who are auto-renewed, at some point after December 15th, they will receive a confirmation message from the FFM about the status of their 2015 enrollment. The message will note whether the family was successfully re-enrolled.
Switching insurers or switching plans
Insurance companies will receive notices of both active and passive re-enrollments, but they won’t receive termination notices for 2014 policies. In other words, when someone re-enrolls and selects a plan offered by a different insurance company, the FFM will not send their former company a notice of their dis-enrollment. However, CCIIO notes that if an insurer does not receive an enrollment transaction notice (either active or passive) from the FFM for a particular enrollee, they should assume that he or she chose not to renew their coverage. Consumers should not have to proactively notify their former insurer that they’ve switched to a new company, but they would be smart to do so, just to be safe.
In addition, the guidance suggests that consumers who choose one plan for 2015 and then switch to another plan during open enrollment will not have to separately notify the insurance company of their first plan – the marketplace will send a “cancel” transaction notice to the first plan.
January premium payments
CCIIO is urging insurers to delay any bank auto-draft payments for January 2015 premiums until the marketplace has acknowledged sending all passive re-enrollments to the insurer. The agency is requiring insurers to “promptly refund” any January payments drawn or mistakenly paid by an enrollee who selected a different insurer for 2015.
Changes in circumstance
Enrollees can report life changes, such as the birth of a baby or marriage, to the marketplace for both 2014 coverage and 2015 coverage during open enrollment. However, after December 15th, enrollees can’t report changes in circumstances for their 2014 coverage through HealthCare.gov. Instead, they must do so through the Call Center. Note that enrollees who have selected a 2015 plan before December 15th will need to report life changes to both their 2014 and their 2015 plan. For example, someone who adds a spouse to their 2014 plan for coverage effective December 1, 2014 will also need to add him or her to their 2015 plan.
CCIIO’s latest guidance is an effort to help insurers and consumers through the re-enrollment process in as smooth and efficient manner as possible. However, there will undoubtedly be points in the process where consumers will get tripped up, and navigators and assisters will need to be there to help them through.