Implementing Health Reform: Renewing Coverage For 2015

Ilustration: Health Reform

On October 15, 2014, the Centers for Medicare and Medicaid Services (CMS) announced, with a month to go before the 2015 open enrollment begins on November 15, that it is beginning to send out notices to enrollees in the federally facilitated marketplace (FFM) explaining to them how to renew their coverage for 2015.

CMS is urging consumers to come back to the marketplace as it opens on November 15 to update their 2015 application and to make sure they are enrolled in the qualified health plan (QHP) that best meets their financial situation and health needs for 2015. The procedure outlined in the announcement is that set out in the FFM redetermination guidance issued in June. State-operated exchanges are also, presumably, beginning to inform their enrollees regarding their own 2015 redetermination processes.

Redetermination Notice

FFM Consumers will receive one of six notices. Consumers who visited the marketplace in 2014 and were determined eligible for coverage, but who did not enroll, are being sent a notice urging them to return to the marketplace and enroll when the open enrollment period begins. Consumers who enrolled for 2014 but have not been receiving tax credits — because they were not eligible, did not apply, or were determined eligible for tax credits but declined assistance — are urged to return to the marketplace and reenroll in coverage.

Those who were enrolled in coverage and received premium tax credits for 2014, and who authorized CMS to access their tax return information to update their eligibility, will receive one of three notices. Those whose 2013 tax information indicates that they had income for 2013 above 500 percent of the federal poverty level will be told to return to the exchange to update their financial eligibility information by December 15. If they fail to do so, their premium tax credits will cease on December 31. Those whose 2013 tax returns indicated that their income was between 350 and 500 percent of the federal poverty level will be told that they should return to the exchange and update their financial eligibility information to avoid having to repay part of their credits at 2015 tax filing time, as available information indicates that they have had a significant change in income.

Those whose 2013 tax returns indicated that their income had not changed significantly will also be urged to return to the exchange to ensure that they receive the right amount of tax credit for 2015 and are in the most appropriate QHP.  Enrollees whose 2013 income is below 500 percent of the poverty level will be told that if they do not update their financial information, they will receive the same amount of tax credits and cost-sharing reduction payments for 2015 that they received for 2014. The relatively small number of enrollees who did authorize the FFM to access to their tax filing information will be told that their financial assistance will terminate if they do not come back to the marketplace and update their information.

Each of the alternative notices lists the persons (if any) who are enrolled in the coverage group of the primary enrollee and who fit the criteria for the notice. Enrollees are told that if they are enrolled in coverage through the FFM by a QHP insurer that will be offering coverage for 2015, they will by November 15 receive a notice from their QHP insurer informing them that they are being reenrolled in either the QHP they were enrolled in for 2014 or, if it is not available, a similar plan. In the few instances where QHP insurers have left the marketplace, enrollees are told that they must return and choose a new plan.

Staying Covered Through The Marketplace

Enrollees are urged by the notice they receive, and by a separate “5 Steps to Staying Covered” document, to:

  1. Review the letter they will receive from their health insurer with reenrollment information, contact their insurer if they have any questions, and write down the 14 digit plan ID number of the plan they will be reenrolled in if they do nothing.
  2. Update their marketplace account, resetting their password if necessary, and updating income, household, and other personal information, to ensure that their financial eligibility information is current and to avoid over- or under-payment. Information that should be reported includes moves, household size changes, qualification of household members for other health coverage, and changes in immigrations status or incarceration of household members. Ninety percent of the information on the online application will be already filled out or pre-populated, but enrollees must ensure all information is current. Enrollees may also use the call center (which will be staffed by 1,000 more representatives than last year) or in person assisters to update their information.
  3. Compare available plans for 2015. Enrollees should do so carefully as relative plan premiums are likely to have changed, and the plan that was the least or second-least expensive plan for 2014 may not be so for 2015. Also networks and formularies may have changed and may no longer be appropriate for the enrollee.
  4. Choose a plan that meets their health needs and budget. Enrollees can simply enter the plan ID number they get from their insurer if they choose to stay with the same plan, but must visit the plan compare site to decide.
  5. Enroll by December 15 to ensure continuous coverage for January 1. Individuals can change plans at any time up to February 15, but changes made after December 15 will not be made until February 1, changes made after January 15 until March 1.

The notices are available in English and Spanish, and have tag lines in 15 other languages directing recipients to the call center for an interpreter. They also remind American Indians and Alaskan Natives that they can change plans outside the open enrollment period. The announcement states that this is only the first of many efforts to reach existing marketplace consumers, and that outreach will continue through mail, email, digital market efforts, and calls.

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