Putting what health insurance agents and brokers do, and have always done, on official government paper can make even a relatively simple, clear-cut process look more complicated.
The managers of the public health insurance exchanges operated by the U.S. Department of Health and Human Services (HHS) have demonstrated that point in a new bulletin that details how 2015 reenrollment will work at HHS-run exchanges.
The bulletin comes from the Center for Consumer Information and Insurance Oversight (CCIIO).
The Centers for Medicare & Medicaid Services (CMS) manages the HHS-run exchanges.
CCIIO is the division of CMS that actually gets down in the exchange trenches and tries to make the HHS exchanges — including the HealthCare.gov exchange enrollment system, and the HHS exchanges’ call centers — work.
In the new bulletin, CCIIO officials talk about passive reenrollment — efforts by consumers to do nothing and keep the same HHS exchange coverage in place — and active enrollment, or mandatory or voluntary efforts by consumers to change coverage.
Some sections in the bulletin deal with how the HHS-run exchanges will handle a National Producer Number (NPN), and how an NPN system that was associated with an HHS exchange enrollee in 2014 should stay in the enrollee’s enrollment file until the enrollee takes active steps to remove it.
A much longer section deals with lists of 20 scenarios, or situations that could crop up during the 2015 coverage enrollment period.
For a look at five of the scenarios that caught our attention, read on.
1. A consumer who is new to the exchange system signs up for one HHS exchange qualified health plan effective Jan. 1, 2015, then replaces it with another QHP that will be effective Feb. 1, 2015.
An assister is supposed to use the “834 enrollment transaction” maintenance code EC. For the first QHP, the subscriber has the subscriber ID number “New.” The exchange needs effectuation confirmation both when the consumer signs up for the first plan and when the consumer switches to the new plan.
The switch in QHPs will be recorded as a change in circumstance transaction but will require no update to the 2015 exchange application, officials say.
2. An enrollee who has been getting the tax credit subsidy fails to pay the November 2014 premium. The consumer is automatically reenrolled into the same product effective Jan. 1, 2015, thanks to a grace period provision, but fails to pay all premiums before the grace period expires Jan. 1.
In this case, officials say, the issuer can terminate the 2014 coverage effective Nov. 30, 2014, then cancel the renewal coverage effective Jan. 1, 2015.
Two 834 transactions are required.
3. A woman with exchange coverage has a baby Dec. 5 and gets her baby special enrollment period (SEP) coverage for 2014, but she does not send in a 2015 coverage application.
The exchange will passively reenroll her in 2015 and also reenroll her baby into 2015 coverage. CCIIO officials note that, starting Dec. 16, 2014, plan changes must be reported to the HHS exchange call center, so that the exchange can help with updating both 2014 coverage and 2015 coverage.
4. A 2014 exchange plan enrollee calls to add a new spouse through a special enrollment period (SEP) Nov. 18. Both spouses get coverage from an insurer that’s different from the one the original enrollee started out using.
Neither of the spouses sends in an application for 2015 coverage. The exchange keeps them both in the plan they switched to Nov. 18, during the SEP.
5. A woman with exchange coverage who was reenrolling for 2015 passively tries to add a new baby to her coverage via HealthCare.gov on Dec. 18 — and can’t.
The new mom has to call the exchange call center to get her baby added to both the 2014 and 2015 plans. She will have to update both her 2014 application and her 2015 application, because the passive enrollments have been processed.
See also: Need health coverage now? Get a kid