Sunday, March 22, 2020

Emergency Special Enrollment Periods in 12 state ACA marketplaces: How easy?

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Update, 4/7/20: Early emergency SEP data collected by Charles Gaba indicates that states that require a phone call to begin the SEP application are seeing slower enrollment than states where an emergency SEP application can be completed online.

Twelve of the thirteen states (including D.C.) that run their own ACA marketplaces have announced emergency Special Enrollment Periods to help the uninsured get covered while the Coronavirus rages. Washington state was first to announce a SEP,  on March 10. CMS is "evaluating" following suit for the 38 states using the federal platform, Idaho is the only holdout (and only red state) among the SBEs.

Kudos to the states that have taken the plunge. May it go smoothly operationally. Some began with some messaging confusion, e.g., info about the emergency SEP that seemed contradicted by older messaging about conventional SEPs, granted only to individuals for life changes such as job loss instead of to anyone seeking insurance. Most of those have been straightened out, but some mixed messaging lingers.  Below, a sampling of clear and not-so-clear home page messaging.

First, a process note: In three states, Washington, Connecticut, and Nevada, an emergency SEP application must start with a phone call rather than an online application. New York requires a phone call to complete the SEP application. In Nevada, applicants have to personally attest that they were not previously enrolled in individual market coverage for 2020; once that is verified, call center staff will "open the gate," as Heather Korbulic, executive director of the Nevada exchange, put it in a phone conversation.  The exchange is aiming to flag those who were terminated for nonpayment earlier this year and have them "work with the carrier" to get reinstated.

Other states that require phone calls may be seeking to address similar concerns. In California, in contrast, the enrollment process for anyone seeking coverage now works exactly as in Open Enrollment season -- no extra steps. That seems to be the case in Massachusetts, Minnesota, Colorado, DC and Rhode Island as well, though I haven't verified that an application can be completed online with no extra steps in each of those states, as in Open Enrollment.

Now, on to how different SBEs present the emergency SEP.

Announcing its emergency SEP on March 11, Massachusetts set a standard, with an un-missable banner prominently displaying a button to get an enrollment process started. The "apply now" button takes the user straight to a page where an account can be created.

Covered California is a little less explicit about what's triggering the immediate opportunity to enroll, but the invitation on the home page can't be missed (my highlight on the right).

The lack of specificity may be because California already had a SEP effectively open to all before the COVID-19 crisis exploded. Because the state had implemented an individual mandate for 2020, the excuse for offering a special SEP effectively open to all was apparent widespread ignorance of the new state-based requirement to carry coverage.

DC, Rhode Island and New York also have clear messaging on the home page that leads easily to starting an application. So does Colorado, albeit with a slight glitch: the text box announcing the COVID-19 SEP rotates with one explaining how ordinary SEPs work, as well as with a third more generic "we've got you covered" box-message. All can lead fairly straightforwardly to an application start, though the ordinary SEP path may cause some confusion.

On Access Health Connecticut, rotating messages may cause more serious confusion. These three banners roll in sequence:

Rolling messages are hard to pick up, especially when they're small.  Clicking on either of the two SEP banners lead to instructions to call the help line, but the COVID-19 SEP could be missed.

Maryland also blurs the message somewhat. Two separate text areas on the home page reference a COVID-19 SEP. One is a banner with no link. The other has a link on the word "enroll," but leads to an information page with lots of text that tells you to visit the website you're on. In fact the only path to starting an application that I see is literally right between the two COVID-19 notices, and it's not entirely clear that it offers marketplace enrollment to all comers now:

Medicaid or life events? You have to put 1+1 together to click on this if you've had no personal "life event" to trigger coverage.

Vermont, the last SBE aboard the emergency SEP train so far, seems to be grappling with some ambivalence about the emergency offer. Try plucking the SEP info out of the top matter here:

Worse, if you click on the "get started" button, you go to a page with the pre-crisis SEP info, with no reference to the emergency SEP.

Needs work, Vermont.

What about  It's been intimated to me that CMS is not mulling whether to open a SEP but working on getting it right logistically, working with insurers in 38 states. Operationally, SEPs are not entirely simple. New York, for example, opened a SEP on March 16 running through April 15 and announced that all enrollments, including those executed after April 1, would be effective April 1.  That can be tricky; some people may not want to pay for retroactive coverage. In Nevada, if you apply by 4/1 coverage starts on 4/1, if you apply between 4/2 and 4/15 coverage will start on 5/1/20.  CMS will have to come up with a rule for 38 states. In a mid-month enrollment, should enrollees have the option to pay for coverage of the month partly gone by? Might that coverage be prorated?

However the logistics are worked out, the nation needs an open enrollment period -- not least because it may stimulate many who are Medicaid-eligible to apply, notwithstanding that Medicaid enrollment is available year-round.  Restoring the funding for nonprofit enrollment assistance that the Trump administration gutted in the 38 states would also help enormously (state-based marketplaces have their own funding base for enrollment assistance -- user fees paid by the insurers selling on the exchange, which in states go to the federal government). Democrats should get that funding into any stimulus going forward. 

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