Wednesday, February 23, 2022

New Jersey launches year-round marketplace enrollment at incomes below 200% FPL

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My last post delved into CMS's motives and goals in establishing continuous year-round enrollment for ACA marketplace enrollees with income up to 150% FPL, as long as benchmark silver coverage remains free to that income level.

New Jersey has gone the feds one better, today announcing year-round enrollment on GetCoveredNJ, the state exchange, for enrollees with income up to 200% FPL ($25,760 annually for an individual; $53,000 for a family of four). 

Various state-specific conditions suggest motives for going that high:

1. Supplemental state subsidies provided in New Jersey make silver coverage free all the way to the 200% FPL threshold. In finalizing its rule establishing continuous enrollment to 150% FPL, CMS suggested (pp. 91-92 here) that limiting the open enrollment to those for whom benchmark coverage is free limits the risk of adverse selection. For that reason, CMS conditions extending the continuous SEP beyond this year on extension of the enhanced subsidies provided through 2022 by the American Rescue Plan.

2. New Jersey is one of a handful of states that imposed a state-level individual mandate after the Republican Congress zeroed out the penalty for the federal mandate. There has been a degree of buyer's remorse about the mandate among progressive groups. It was enacted in 2018 to partly fund a state reinsurance program (about two thirds-funded by the federal government), which reduced premiums for unsubsidized (i.e., mostly affluent) enrollees. Most people who pay the mandate penalty are low income. Continuous enrollment, along with the targeting of uninsured taxpayers described below, would reduce low-income exposure to the mandate.

3. The New Jersey legislature passed an "easy enrollment" bill late last year, conditionally vetoed by Governor Murphy but likely to be amended and passed, that would use tax returns to identify uninsured and likely Medicaid-eligible or marketplace subsidy-eligible taxpayers and provide a check-box on the tax form authorizing the state to check their eligibility for coverage. The individual mandate penalty would be waived for those who enroll. Continuous enrollment in the marketplace (as is available in Medicaid) would remove a friction point for those with income under 200% FPL, as those applicants would not have to apply for a personal Special Enrollment Period.

4. As a state that has expanded Medicaid and as a high-income state, New Jersey has relatively few marketplace enrollees with income in the 100-150% FPL range (15% of enrollees in 2021, compared to about 50% in nonexpansion states), and a larger share in the 150-200% FPL range (24% in 2021). The SEP to 200% FPL will be available to more than 40% of enrollees (as perhaps 4%* have incomes under 100% FPL).

5. With the end of the federal moratorium on Medicaid disenrollments looming, continuous enrollment to 200% FPL in the marketplace should provide at least a modest assist to the effort to minimize coverage losses or help those who do lose coverage regain it quickly.

6. The New Jersey legislature and executive branch have partially funded and enacted a drive to Cover All Kids in the state, and the state has also established a Health Insurance Affordability Fund -- funded with a state assessment on health insurers that replaced the repealed federal tax -- with a mandate to improve affordability at incomes below 400% FPL and reduce racial disparities in access to care. The new continuous enrollment initiative is a further effort to "promote health equity," according to the state's Department of Banking and Insurance Commissioner Marlene Caride (in the press release cited above).


* In 2016, HHS reported the percentage of enrollees in each state with income below 100% FPL and has never done so since. In New Jersey, 4% were below that threshold.  A majority of enrollees with incomes below 100% FPL are likely legally present noncitizens subject to the federal 5-year bar for Medicaid enrollment. The ACA granted marketplace subsidy eligibility to people in this situation.

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Photo by Artem Beliaikin from Pexels

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