As August winds to a close, at Georgetown CHIR our thoughts turn not to pumpkin lattes and back-to-school school outfits but to health insurance. That’s because we’ve already started work to update and improve our Navigator Resource Guide, thanks to the generous support of the Robert Wood Johnson Foundation. The Guide provides information on recent federal policy changes affecting the Affordable Care Act (ACA) marketplaces, enrollment resources for consumer assisters, and answers to hundreds of frequently asked questions (FAQs) about eligibility for marketplace insurance and subsidies, individual market and small employer coverage, and post-enrollment issues. Our updated Navigator Guide will include FAQs on new and emerging issues that will confront consumers and employers this open enrollment season, such as:

• The U.S. Department of Homeland Security’s “Public Charge” rule, which broadens the types of public benefits that would count against an immigrant’s application for admission to the U.S. or permanent residency. While marketplace premium tax credits are not on the list of “public benefits” in the rule, assisters working with immigrant communities need to be aware of potential risks associated with applying for marketplace coverage. Unless halted by a legal challenge, the rule is scheduled to go into effect October 15, 2019, just prior to open enrollment.
• Newly available Health Reimbursement Arrangements (HRAs), which employers may offer in lieu of a group health plan. HRAs are accounts that employees may use to purchase individual market health plans. Small employers are likely to have questions about the risks and benefits of offering HRAs, and consumers with HRAs are likely to have questions about where and how to sign up for HRA-reimbursable coverage.
• A New Special Enrollment Period is available to people with individual market insurance who experience a mid-year change in income that makes them eligible for marketplace financial assistance. Previously, such individuals would have to wait for the next open enrollment season to obtain marketplace tax credits or cost-sharing subsidies.
• Association Health Plans (AHPs) have been promoted by the Trump administration as a cheaper alternative to ACA-compliant insurance. Although these new AHPs have been barred from marketing to new enrollees under a court order, current enrollees may have questions for Navigators about their ability to re-enroll, or whether and how to obtain ACA-compliant coverage.
• Direct enrollment through web-brokers. The Trump administration has approved several private web-brokers to serve as alternative portals for obtaining a determination of eligibility for marketplace subsidies and enrolling in a marketplace plan. Navigators are likely to field questions from consumers about these alternative websites and the risks and benefits of using them compared to HealthCare.gov or official state marketplace sites.

These new federal policy changes are in addition to numerous changes that were implemented last year, including the elimination of the individual mandate penalty, the availability of short-term health plans, and the potential loss of ACA subsidies for enrollees who fail to file and reconcile their federal taxes.

The updated and improved Navigator Resource Guide will be re-launched in October. You’ll be able to access FAQs on the above topics and more here.