Fall is here and with it a shift in the types of questions we’re getting from Navigators under our Robert Wood Johnson Foundation-funded project to provide them with technical assistance. Since open enrollment ended last Spring, most of the questions from the field have involved special enrollment periods or Medicaid and CHIP eligibility issues. This week we received a question from someone already thinking about challenges around the corner: re-enrollment for 2015, which begins November 15^th and ends February 15, 2015.

In this particular case, an enrollee was concerned about the consequences of being dis-enrolled from her stand-alone dental plan (SADP) for not paying her premiums. Because of a technology glitch with healthcare.gov, if an enrollee drops her SADP plan, the current federally based Marketplace system automatically dis-enrolls her from her health plan, if she purchased both at the same time. In this case, the enrollee was advised that, to keep her health plan but drop her SADP, the only way to do so is to stop paying premiums for the SADP but continue to pay premiums for her health plan. This may be an issue for the upcoming year as well because CMS has indicated that for the upcoming open enrollment, the marketplace will require returning enrollees to confirm their health plan and SADP at the same time.

The enrollee was concerned about how her non-payment of premiums for the SADP would affect her at the upcoming Open Enrollment. Would she be denied coverage in her health plan or a new SADP for non-payment of premiums? As discussed in a recent blog, an insurer is prohibited from denying an enrollee a health plan during open enrollment because he or she failed to previously pay premiums under the guaranteed issue provisions of the Affordable Care Act (ACA). The guaranteed issue provision requires an insurer to offer and accept any individual that applies for a health plan it is offering, which includes an enrollee that previously failed to pay premiums. The guaranteed issue provision of the ACA, however, does not apply to a SADP. Thus, an insurer offering SADP could deny an individual because of failing to previously pay premiums. Some states, however, may offer additional protection and extend guaranteed issue to SADP.

Thus, unfortunately, while this enrollee should be guaranteed the right to re-enroll in her health plan, or any health plan, it’s possible a SADP could deny her coverage.

Editor’s Note: CMS has put out written guidance on the issue of canceling dental coverage, but maintaining health coverage.  See below.

Dental Coverage

Q9 (UPDATED Q&A):  A consumer is enrolled in both dental and medical coverage through the Marketplace but no longer wants to have dental insurance. Can the consumer only cancel the dental coverage and keep the medical coverage?

A9: The Marketplace HealthCare.gov website and Call Center do not currently have the functionality to allow a consumer or one of his or her dependents to be removed from a Marketplace dental plan while maintaining enrollment in a medical plan. However, if a consumer has separate medical and dental policies and wants to cancel only the dental plan, the consumer can do so by not paying the dental plan’s premium, which will cause the dental coverage to terminate. As long as the consumer continues to pay the medical plan premium, the consumer will maintain enrollment in the medical plan. It is very important for consumers to be reminded that to avoid being terminated from any plan, enrollees must pay, in full, the portion of the premium for which they are responsible prior to the end of the applicable grace period for plans they wish to maintain.  Consumers should continue to pay their premium for their medical coverage even if they stop paying the premium for their dental coverage, if they want their medical coverage to continue.