Feds offer PPACA plan do-over

CCIIO Director Gary Cohen (CMS photo) CCIIO Director Gary Cohen (CMS photo)

The U.S. Department of Health and Human Services wants to help managers of troubled insurance exchange programs pretend that the weeks of technical glitches were a bad dream.

Officials at the Center for Consumer Information & Insurance Oversight talks about an exchange enrollment do-over option in a bulletin sent to exchange managers.

Open enrollment closes March 31. 

CCIIO has had problems getting HealthCare.gov, to work properly, and many states have had problems with their own enrollment sites.

If consumers were unable to enroll in qualified health plans – private exchange plans – through an exchange because of technical problems, HHS might regard that as an “exceptional circumstance,” CCIIO officials write in the bulletin.

HHS wants to let exchange managers provide retroactive coverage for consumers affected by the exceptional circumstances, CCIIO officials say.

If a consumer applied for plan coverage through an exchange and ended up with none at all, or with non-exchange plan coverage and no PPACA advance premium tax credit subsidy payments, an exchange could let the consumer enroll in subsidized plan coverage after the consumer got through the complete application process, officials say.

The consumer’s effective enrollment date would be the date when the consumer submitted an application for coverage, rather than the date when the consumer got through the application process, officials say.

In that case, HHS would base any premium tax credit subsidy payments – and any payments for helping consumers with plan deductibles – on the effective enrollment date, not the date when the consumer finally got through the application process, officials say.

If the consumer was without coverage while waiting to complete the plan application process, the carrier would have to collect and pay the claims the consumer incurred while uninsured, officials say.

If the consumer had non-exchange plan coverage while waiting to get through the application process, then shifted into the exchange version of the plan, the carrier would have to re-adjudicate the consumer’s claims as if the consumer had been in the exchange plan on the effective enrollment date.

An exchange that uses the guidance given in the bulletin cannot discriminate in favor of certain plan providers, officials say.

An exchange “should be consistent in its treatment of issuers when applying effective date rules,” officials add.

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