This year, for the first time, consumers who have been getting Patient Protection and Affordable Care Act (PPACA) health insurance subsidies were supposed to file tax returns documenting their use of the PPACA premium tax credit and PPACA cost-sharing reduction subsidies.
Consumers who got their coverage, and their subsidies, from the public exchanges managed by the U.S. Department of Health and Human Services (HHS) were also supposed to be telling the exchanges, within 30 days, about any events that might have affected their eligibility for coverage.
Now, the Centers for Consumer Information and Insurance Office (CCIIO) has come out with the procedures it expects to use to move forward for the 2016 open enrollment period when exchange users seem to be earning too much to qualify for PPACA subsidy programs, have refused to let the exchange system check their tax return information automatically, or have failed to file tax returns documenting PPACA subsidy use.
See also: IRS summarizes PPACA individual mandate rules
CCIIO is an arm of the Centers for Medicare & Medicaid Services (CMS), a major HHS division.
CCIIO oversees the PPACA exchange system and other HHS programs created by PPACA that affect the commercial health insurance market.
The 2016 open enrollment period is supposed to start Nov. 1, 2015, and end Jan. 31, 2016.
An HHS-run exchange, or “marketplace,” will send a MOEN to any 2015 PPACA exchange application filer in a family or household that has exchange plan coverage and has not arranged to cancel all of the exchange coverage. The MOEN will include extra premium tax credit and cost-sharing reduction information for exchange users who have been using PPACA subsidies. The MOEN will also include special content aimed at four groups at risk of facing serious re-enrollment problems.
The new “annual eligibility and re-enrollment” guidance will have a direct effect only on the HHS-run exchanges, but it could have an indirect effect on how state-based exchanges handle eligibility re-determinations.
From the look of the guidance, the MOENs may be complicated enough to create a flurry of business for agents who can help consumers figure out the MOENs.
For a look at what will happen to four groups of 2015 exchange plan users facing potential 2016 re-enrollment crises, read on.
1. Special notice group
These are 2015 exchange plan enrollees who are getting insurance subsidies, let the exchange check their tax information automatically, and look as if they’ll be swimming in money in 2016, because they now appear to have income over 500 percent of the federal poverty level.
If members of that group fail to contact an exchange and update their information, the exchange will try to re-enroll them in 2016 coverage automatically, if that’s possible, without providing any PPACA coverage subsidies.