Roughly fifteen million people are projected to lose Medicaid coverage following the end of the federal COVID-19 public health emergency (PHE). About five million people in the disenrolled population are expected be eligible for federally subsidized coverage through the Affordable Care Act marketplaces. As state insurance regulators and marketplace officials prepare for this massive coverage transition, one goal is to ensure that brokers and enrollment assisters are doing all they can to help those losing Medicaid eligibility understand their coverage options and enroll in a plan that suits them. However, there are warning signs suggesting consumers in some states will find help harder to come by, with several insurers eliminating broker commissions for mid-year marketplace enrollment.

In a new Expert Perspective for the State Health & Value Strategies project, CHIR’s Justin Giovannelli looks at the consequences of cutting commissions for special enrollment periods (SEP). Reducing or eliminating broker commissions for SEPs puts consumers at risk of coverage loss after the PHE, and may weaken the individual market risk pool. Additionally, this marketing practice likely violates federal nondiscrimination rules. States should continue to keep a close eye on broker commission arrangements, and consider acting to head-off compensation schemes that discourage mid-year enrollment, including by the many Americans who will soon be searching for new coverage at the end of the PHE. You can read the full post here.