Public Marketplaces/Exchanges Still Open!
Despite numerous reports of the “closing” of the Affordable Care Act’s (ACA) public health insurance exchanges/marketplaces on March 31, 2014, THEY’RE ACTUALLY STILL OPEN FOR BUSINESS! Media reports stating that “the exchanges are closed” are simply inaccurate. Much like group health insurance plans, ACA marketplace/exchange plans have two (2) enrollment periods:
- Open Enrollment – which ran from 10/1/13 – 3/31/14 in the inaugural year of the launching of the public marketplaces/exchanges. IMPORTANT: The Department of Health and Human Services (HHS) announced on March 26, 2014 that it would extend the open enrollment deadline for consumers to enroll in a public marketplace/exchange health insurance plan if they started enrollment before March 31 but weren’t able to complete the application by midnight.; and
- Special Enrollment – qualified individuals have another opportunity to obtain coverage both on and off the the public marketplaces/exchanges, on a guarantee issue basis, with all the other ACA related provisions (e.g., community rating, 10 essential health benefits, no pre-existing condition limits, etc.). Such an opportunity, referred to as a “special enrollment period” is triggered by one or more “circumstances”, including, but not limited to the following:
- loss of coverage (generally involuntary; the lost coverage must meet the ACA’s “minimum essential coverage” guidelines);
- gaining or becoming a dependent through marriage, birth, or adoption;
- becoming a citizen, national or legally present;
- mistake by the marketplace/exchange or the department of Health and Human Services (HHS);
- contract violation by a plan or certain misconduct on the part of a non-Exchange entity providing enrollment assistance or conducting enrollment activities;
- change in eligibility for federal subsidies;
- gaining access to a new qualified health plan due to a permanent move; or
- other exceptional circumstances (defined by the particular State/Federal exchange/marketplace).
Eligible individuals may still purchase subsidized coverage from a Public marketplace/exchange during a special enrollment period.
Click here for a link to specific guidance relative to special enrollment periods – https://www.healthcare.gov/how-can-i-get-coverage-outside-of-open-enrollment/
Special enrollment periods are generally 60 days from the date of the triggering circumstance or event. Coverage effective dates follow the rules that apply to open enrollment, which is the first of the month following enrollment made by the 15th of the preceding month.
[Example: coverage applied for between 6/1/14 – 6/15/14 becomes effective 7/1/14.]
And finally – open enrollment for 2015 will run 11/15/14 – 2/15/15, allowing both new enrollments and changes to existing coverage. This is a shorter enrollment window of time than was allowed for the 2014 enrollment season.