The board of the Connecticut Health Insurance Exchange agreed unanimously in Hartford on Thursday to propose requiring consumers who seek to use special enrolment periods (SEPs) to provide documentation for at least five different types of SEP requests.
The board of the state-based Patient Protection and Affordable Care Act (PPACA) public exchange, which does business as Access Health CT, will publish the proposed SEP documentation requirement in the Connecticut Law Journal.
Once the proposal is published, consumers will have 30 days to comment, according to documents included in a board meeting packet.
PPACA now bans use of most of the techniques health insurers once used to hold down claim risk. PPACA drafters tried to compensate for that by using premium tax credit subsidies, and a penalty imposed on many individuals who lack minimum essential coverage (MEC), to encourage healthy people to buy coverage and subsequently reduce the overall average level of claim risk per enrollee.
Regulators, public exchange managers and insurers developed an open enrollment period system, or system limiting when people can automatically qualify to buy health insurance, to keep healthy people from waiting until they get sick to pay for coverage. To buy coverage outside the open enrollment period, consumers are supposed to qualify for a SEP. Exchange plan users can get SEPs when they lose access to MEC or qualify for a variety of others reasons.
Some insurers have complained about frequent SEP abuse. Consumer groups in states such as California have questioned whether insurers have solid evidence that SEP abuse is common, and they say documentation requirements could cause problems for struggling consumers who need help the most.
The new Access Health CT proposal would require applicants to document eligibility for SEPs based on the following triggers:
Loss of MEC.
Permanent move to Connecticut.
Adoption, placement for adoption, placement for foster care, child support or other court order.
“The exchange may also require verification documentation with respect to other triggering events as deemed necessary by the exchange,” according to the board’s procedure summary.
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