It’s all about enrollment as we count down to Open Enrollment 3 less than a month away. One resource that will come in handy is the FFM and FF-SHOP Enrollment Manual that the Centers for Medicare and Medicaid Services (CMS) recently published. Chock full of all things related to enrollment, the almost 150-page guidance document provides operational policy and guidance related to FFM and FF-SHOP eligibility and enrollment activities. In particular, the Enrollment Manual covers the following topics:
- enrollment for individual (FFM) and small-group coverage (FF-SHOP)
- special enrollment periods (SEPs)
- premiums, including grace periods
- enrollment reconciliation
According to CMS, the Enrollment Manual replaces the Enrollment Operational Policy and Guidance from 2013 and supersedes all previous bulletins that CMS published in the last couple of years. Going forward, CMS will update the Manual periodically and use bulletins to clarify any enrollment issues as needed until the next update. One such bulletin will likely be CMS’ policy on the proration of premiums and advance premium tax credits, which CMS indicates is still pending (section 6.2 of the Enrollment Manual). In addition to policy guidance, the Enrollment Manual provides numerous examples to clarify CMS policy such as examples related to terminations for the non-payment of premiums, grace periods spanning two years, and under-billed premiums by an insurer. Also helpful are the numerous exhibits throughout the Manual listing specifics like the process for reporting a life change, the qualifying life events for a special enrollment and their effective coverage dates, and marketplace granted SEPs. Other exhibits are flowcharts detailing activities like the enrollment process between the marketplace and an insurer or the FF-SHOP issuer payment process. The Manual also contains three sample notice letters related to the initial enrollment (i.e., welcome), non-payment of premiums, and termination and a sample attestation for premium tax credits in the appendix section. Given the breadth of covered topics, the new Manual is a helpful resource for anyone interested in FFM and FF-SHOP enrollment.