On August 28, 2017, the Centers for Medicare and Medicaid Services released information providing insight into the procedures that it intends to follow for the 2018 open enrollment period. There are some new policies in place for the 2018 plan year, many of which have been introduced by the market stabilization rule:
CMS has announced a new rule which will permit payments for new enrollees to be applied for past-due premiums owed to the insurer or an insurer in the same group. According to the released information, if payment of applicable past-due premiums and a new binder is not received for the new coverage, the insurer may refuse to effectuate coverage. The rule will allow a look-back period of up to 1 year, however the look-back period for 2018 coverage cannot extend beyond June 19, 2017. Insurers must have described its nonpayment policy in its application materials and in any notice of nonpayment of premiums. The policy may only be applied to enrollees that have received notice before failing to pay their premium that has become past-due, and only to enrollees who were contractually responsible for the nonpayment.
CMS will conduct two waves of batch auto-enrollments (BARs) similar to what occurred during the 2017 plan year. Wave 1 will reach issuers between October 10-31 and will include alternative enrollments. These enrollments will include those that required CMS or a state’s department of insurance to select an alternative plan for individuals with 2017 coverage from an insurer that is no longer available. The second BAR Wave has been scheduled for after December 16. This wave will include enrollments with special enrollment periods that occurred late in the year and active re-enrollees who started an application but has not enrolled prior to being batch-autorenewed.
Dual QHP and Medicare
Dual QHP/Medicare Enrollees will be auto-enrolled for 2018. Despite this, insurers that know that enrollments contain a QHP enrollee that is entitled to Medicare Part A or enrolled in Medicare Part B are instructed to non-renew the entire policy covering the Medicare individual. This goes into effect if the QHP reenrollment is a change of policy or contract under state law and duplicates Medicare. As a result, insurers should direct enrollees, impacted by the canceled policy and who are eligible for QHP coverage, to the federal exchange to update their application and enroll in coverage.
This October, insurers will be required to reach out to individuals in danger of losing their premium tax credits and cost-sharing reductions. This may include those consumers who have not authorized the IRS to release their tax information to the exchange, have received a special notice because the IRS reports their income as exceeding 500 percent of the poverty level, have failed to reconcile their advance premium tax credits (APTC) and actual premium tax credits in the past, or applied in 2014 or 2015 and were auto-enrolled for two years but have no available tax data.
Duplicate Active Enrollments
CMS has announced that, from November 3 through December 15, insurers can expect daily notifications on enrollees that have switched to another insurer. In addition to this, weekly notifications will be provided to insurers to cancel passive enrollments that duplicate active enrollments. In January, CMS will contact insurers to inform them of the enrollees that were not auto-reenrolled due to processing issues. Utilizing this information, insurers are expected to reach out to impacted consumers to encourage them to actively reenroll.
Renewal notices must be sent prior to open enrollment and subsequently send a January bill in December with the enrollee’s current APTC information. According to the guidance released by CMS, Insurers are strongly encouraged to stress that enrollees must update their applications, review available plans, and choose a plan by December 15.
Auto-enrollment is invisible to consumers until December 16, and insurers are not supposed to tell consumers they are auto-enrolled before that date, but rather urge them to enroll actively. Insurers who have had enrollees switched to them from plans that are no longer available should hold off billing until open enrollment ends so as not to discourage enrollees from active enrollment. Enrollees who have been enrolled in an alternate plan because their 2017 insurer is no longer available should be sent information about the new plan by their new insurer, be encouraged to consider active shopping, but be told that if they fail to act they will be enrolled in the alternate plan
Senate Schedules Hearings to Craft Bipartisan Healthcare Bill
The Senate Health Committee has scheduled two more hearings in addition to those scheduled for the week of September 4. These two meetings are aimed at assisting members of the committee with drafting a bipartisan healthcare bill utilizing opinion and recommendations from industry experts (September 12) and stakeholders (September 14). The committee has announced that it is looking to assemble a bipartisan bill by the end of September, which would be enacted to help stabilize the Affordable Care Act (ACA) marketplaces. While there is little information available on the proposal, the Hill has disclosed that the bill is likely to include funding for CSR payment to insurers as well as changes to the law’s state waivers.
CMS Ties 2018 Navigator Grants to 2017 Performance
CMS has announced that the next set of health insurance navigator organization grants will be based on their success in meeting 2017 enrollment goals. According to the agency, if an insurance navigator organization was successful in meeting 30%, for instance, of its 2017 enrollment goal, then it can expect to receive 30% of the funding it received for 2017. The announcement did not provide insight into CMS’ methodology for calculating 2018 grant amounts, or if a navigator organization exceed its goal for last year.
For 2017, CMS spent $62.5 million on federal Navigator grants to help Navigators enroll more than 81,426 consumers. This factors in nearly $770 of Navigator funding that was spent on each enrollee. According to Health Access California, Navigator funding could fall to $36 million in 2018.
Latest Map Shows No Bare Counties
Last month, CMS announced that based on rate filings, nearly 40 counties would be with an insurer next year. On August 30, CMS published a map of exchange insurer participation, revealing that there are no counties, or “bare counties”, without insurers offering plans through the exchanges. This follows, CareSource’s decision to sell insurance in Paulding County, Ohio, the last bare county in the United States according to CMS’ August 16 announcement.
CMS projects that 1,476 counties, or more than 45% of nation’s counties, could have one 1 insurer for 2018. Approximately 2.6 million people have been estimated to represent the marketplace enrollees that could have only 1 option for health insurance come open enrollment.
In 2017, approximately 12 million people enrolled into private health insurance coverage through the ACA Marketplaces. The 2018 OEP is set to start on November 1 through December 15.
The views and opinions expressed by the authors on this blog website and those providing comments are theirs alone, and do not reflect the opinions of Softheon, Inc. or any employee thereof.
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