Tuesday, April 21, 2020

HealthCare.gov will not require proof of loss of coverage from the newly uninsured

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CMS has refused to follow the lead of the thirteen state-based ACA marketplaces and open an emergency Special Enrollment Period (SEP) in the 38 states using HealthCare.gov, the federal ACA enrollment platform.  But the agency is taking smaller steps to smooth the enrollment path for the newly uninsured.

An emergency SEP would allow anyone who's uninsured to seek coverage in the marketplace as they can during the yearly Open Enrollment period, which on HealthCare.gov runs from Nov. 1 - December 15. Instead, only those who have have a qualifying "life change" -- e.g., loss of job-based coverage -- can enroll in marketplace plans. That requires applying for a SEP, which is a process in itself.  (Medicaid enrollment is open year-round, but many of the newly uninsured may not be aware if they're Medicaid-eligible -- all uninsured need a general message that coverage of one kind or another is available.)

Yesterday, Amy Lotven of Inside Health Policy reported (paywalled) that CMS has created a new Covid-19 page (parts of which I reviewed in my previous post) -- and, more significantly
CMS is providing flexibility around submission of certain documents, such as a document confirming loss of coverage from one’s employer, during the pandemic emergency, the agency says.
What exactly is "flexibility"? Well, in a webinar for enrollment assisters hosted by a division of CMS, the  Center for Consumer Information and Insurance Oversight (CCIIO), the moderator spelled out that those who lose coverage will not have to document the loss by upload or by mail  -- they can simply attest to it.

That's very good news. As veteran enrollment assister Shelli Quenga of the South Carolina-based  Palmetto Project  explained to me recently:
"The process is deliberately cumbersome, and it's going to cause people to remain without coverage," [Quenga] worries.

First, you need a date  when your coverage ended, and that in itself can be difficult to obtain. Once you have entered that information, the marketplace gives you thirty days to provide documentation -- a letter from your employer or the insurance carrier stating the coverage termination date. A letter offering COBRA, the extension of job-based insurance for which the ex-employee must pay full price, will also serve.  If documentation isn't provided within 30 days, you have to start the application process over again. And you have only a 60-day window from date of coverage loss to be granted a SEP....

All these difficulties are likely to be cubed in the coming tsunami of job loss and loss of insurance. Start with verifying the date that coverage was lost.  It can't be merely inferred. "People lose coverage in the middle of the month, at the end of the month, or at some random date," Quenga says.

Imagining current predicaments, Quenga posits, "You can't just go into your place of business and talk to them because the business is closed. "Your own supervisor may have been laid off. So who are you supposed to talk to?" 
The refusal to open an emergency SEP in HealthCare.gov appears to be a political imperative for senior officials beholden to Trump, who is still trying to nullify the ACA in court and uninsure some 20 million people in the midst of a pandemic. But under the radar, perhaps CMS is trying to do the right thing. Or parts of it.

Update: Charles Gaba has directly quoted from the CCIIO webinar tape:
the Marketplace is not requiring consumers to upload supporting documentation to verify their eligibility to enroll in a Special Enrollment Period. So instead, consumers may attest to that information that they provide on the application while they are applying for a SEP.”
It's not clear whether that documentation waiver applies to all types of SEP or just loss of health insurance.  As Charles points out, though, at present the vast majority of SEP applications are doubtless for loss of coverage. Normally about 60% of SEPs are for that purpose.

Smooth the path to Medicaid enrollment for the newly uninsured
ACA enrollment train wreck coming
Our emerging public option: Medicaid
CARES Act may reduce coverage gap in states that refused to expand Medicaid
Enhanced unemployment benefit will skew marketplace enrollment
Emergency special enrollment periods in 12 states: How easy?
How about an emergency Special Enrollment Period for the ACA marketplace?

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