Officials at the Center for Consumer Information & Insurance Oversight (CCIIO) are trying to flesh out the details of their consumer help process.

One transaction that’s now, inevitably, come up: Questions about what to do when consumers who have enrolled in quality health plans (QHPs) through the Patient Protection and Affordable Care Act (PPACA) public exchange system die.

CCIIO — an arm of the Centers for Medicare & Medicaid Services (CMS), which is, in turn, an arm of the U.S. Department of Health and Human Services (HHS) — has posted a batch of guidance for health insurers on what families or others should do when HHS exchange QHP coverage terminates because the life of the coverage holder terminates.

Officials note that a regulation requires HHS exchange QHP coverage to end on the enrollee’s date of death. Once concern is that any household members who get their coverage through an “initial application filer” who has died will have to find new coverage. 

So, what should an insurer, agent or broker do when they hear about enrollees who have died?

Here are three do’s and don’ts from the CCIIO guidance.

Child on a phone, with an international negation sign over the child's head. 

1. DO tell consumers that they can report enrollee deaths through the HealthCare.gov accounts of the enrollees who have died, or call the exchange call center — but that any callers must be at least 18 years old.

Children cannot call the HHS exchange call center to tell the exchange managers that an enrollee has died. 

HealthCare.gov screen shot

2. DON’T tell consumers who are unable to get into a dead exchange enrollee’s HealthCare.gov account that they are out of luck.

The consumers will be able to report the enrollee’s death. They will simply have to start the process through the call center, rather than online. A caller who meets the HHS definition of an “application filer” can update the application of the remaining members of the household if the deceased was the initial application filer.

Image: AP image/HHS

Checklist

3. DO warn consumers that, if they are not the application filers, and are not included in a dead enrollee’s initial exchange application, they will have to provide documentation of the enrollee’s death.

Documentation could include a death certificate, an obituary, a power of attorney, a proof of executor, or proof of estate.

The documentation or an attached cover note should provide the full name of the dead enrollee; the date of birth of the dead enrollee; the HHS exchange application ID, if known; the Social Security of the dead enrollee; and contact information for the individual submitting the documentation.