The Center for Consumer Information and Insurance Oversight (CCIIO) released last week a new tool to help consumers determine whether they qualify for a special enrollment period (SEP) to sign up for a plan in the federally facilitated marketplace. This screener tool, along with recent rulemaking that allows people to enroll in a marketplace plan 60 days before the expected termination of any minimum essential coverage and not just employer-based coverage, can help consumers more easily manage their coverage options during life changes and help them avoid unnecessary coverage gaps. The screener tool is a welcome step and improves the consumer-friendliness of the site. However, it does need a few improvements to prevent confusing and potentially frustrating consumers.
The tool allows consumers to choose their state of residence and then asks a series of questions, such as: Have you or anyone in your household lost coverage within the last 60 days? Have you had a change in your household size, such as getting married, having a baby, getting divorce, or a death in the family? Have you moved to a new address or had a change in income? The tool also asks if you’ve recently gained U.S. citizenship or lawful residency, been released from incarceration, or are a member of a federally recognized tribe.
So what’s the problem? It’s not the questions themselves – it’s the answers that could confuse or frustrate people. For example, for anyone selecting divorce or death in the family, the tool informs them: “Based on the information you provided, it looks like you qualify for a special enrollment period.” People are told this even when they answer “No” to the question of whether they or anyone in their household has lost or expects to lose health coverage. But under federal rules, neither divorce nor a death in the family would qualify you for a special enrollment period if there weren’t also other changes in your life.
So, for example, if you get divorced but don’t change your employment-based benefits or have a permanent move, under federal rules you are not entitled to a special enrollment period. Similarly, if your spouse dies but you were not on his or her plan (and therefore your coverage doesn’t change), under federal rules you do not qualify for a special enrollment period. Yet nowhere on the screener tool does it let people know that.
If you report a change of income, you’re also told that “”It looks like you qualify for a special enrollment period,” but it doesn’t include any of the caveats written into federal regulations, including the fact that the only way to qualify for a SEP is if you are already enrolled in a marketplace plan. So if you had purchased insurance outside the marketplace but then experienced a loss of income that made you eligible for tax credits, you do not qualify for a SEP.
Unfortunately, this incomplete information will lead a number of people to pursue an application, only to be frustrated and annoyed when they learn later they weren’t actually eligible for a SEP. I applaud CCIIO for highlighting special enrollment periods and developing a tool to make it easier for people to figure out what their options are. The screener tool, along with other recently announced improvements will make it easier for people to connect with the coverage option that’s right for them. But CCIIO does need to make a few changes to ensure consumers get more accurate information.
Editor’s Note: The author thanks Justin Giovannelli and JoAnn Volk for bringing some of the concerns about the healthcare.gov screener tool to her attention.