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May 05, 2016 at 10:25 AM
The Blue Cross and Blue Shield Association says the government could help make the public health insurance exchange application process more honest by developing, and using, special enrollment period (SEP) reason codes.
Justine Handelman, a vice president at the association, gave that recommendation in a comment letter sent to the Centers for Medicare & Medicaid Services (CMS).
CMS is putting the exchange application process through a federal Paperwork Reduction Act (PRA) review. The review process includes a public comment period.
In the Blues’ comment on the exchange application process, Handelman says CMS should:
- Reduce the number of SEPs available to public exchange users.
- Make the types of SEPs available to exchange users more like the types of SEPs available to Medicare Advantage users and commercial health coverage users.
- Have the public exchange system tell consumers more about SEP requirements.
- Let insurers use the kinds of validation processes they commonly use in other markets.
Handelman also talks about ways CMS could improve SEP integrity by setting up a better process for sharing SEP information.
CMS sets guidelines for SEP rules at all PPACA public exchanges. The agency actually runs the SEP program at HealthCare.gov, the public exchange enrollment and administration system that the U.S. Department of Health and Human Services (HHS) set up for states that are unwilling or unable to provide state-based public exchange services.
For the HealthCare.gov states, CMS should develop a separate code for each reason that a consumer could use to qualify for a SEP, Handelman writes.
CMS should then use the SEP reason code when it communicates with insurers about SEPs, Handelman says.
“This will allow issuers to better track and verify SEPs, and more effectively aid in CMS’ program integrity efforts,” she says.
Insurance regulators developed the SEP system in an effort to keep young, healthy people from using PPACA underwriting restrictions as an invitation to wait until they get sick to pay for coverage.
