Some insurers say frauduluent special enrollment period applications are common. (Image: Thinkstock)

HealthCare.gov managers recently gave agents and brokers lists of many types of documents consumers can use to show they qualify for special enrollment periods.

Officials from the Center for Consumer Information & Insurance Oversight, the agency directly responsible for running HealthCare.gov, put the document lists in the slidedeck for a webinar explaining the new HealthCare.gov special enrollment confirmation process.

People who want to buy individual commercial health insurance outside of the official Affordable Care Act open enrollment period now have to show that they have a good excuse to be shopping for coverage. The next open enrollment period, for 2017 coverage, is set to start Nov. 1 and end Jan. 31.

Related: What are ‘special’ PPACA enrollees REALLY like?

In the slidedeck, oversight office officials show, for example, that consumers can submit any of 15 types of documentation to show that they qualify for special enrollment periods, or SEPs, because of the loss of what the government classifies as solid health coverage, or “minimum essential coverage.”

A consumer can send a state’s HealthCare.gov exchange, or “Marketplace,” a letter from an employer that’s dropping health coverage, a letter from a school saying when student health coverage ends, divorce papers showing when coverage obtained through a husband or wife ends or a notice from a government health program saying when the government plan coverage runs out.

Special enrollment periods

If nothing else is available, a consumer can send the Marketplace a “letter of explanation about the coverage you had, why and when you lost or will lose it, and the reason you can’t provide any other documents,” officials say. “The Marketplaces will take your letter into consideration.”

Related: Blues to feds: Use ACA special enrollment tracking codes

Similarly, if consumers qualify for special enrollment periods because they’ve moved, they can use many different types of documents, including letters explaining their lack of ability to obtain documents, to justify requests for special enrollment periods, officials say.

Drafters of the Affordable Care Act set up the public exchange system to help consumers use government premium subsidies to shop for coverage. The U.S. Department of Health and Human Services, the parent of the insurance oversight office, set up HealthCare.gov to provide ACA exchange services in states that are unwilling or unable to do the job themselves.

The ACA drafters also eliminated many of the defenses health insurers once used, such as refusals to sell coverage to people who already had cancer, to limit claim risk.  

Insurers, regulators and ACA exchange managers developed the open enrollment period system, or limits on when people can buy ordinary individual health coverage without showing they have a good excuse to be buying coverage, to keep healthy people from using the new rules to pay for coverage only when they know they’re sick.

HHS officials have been trying to beef up special enrollment period verification processes in response to insurer complaints that exchanges were doing nothing to screen out liars.

Some consumer group representatives and state-based exchange managers have questioned whether special enrollment period fraud is common, and whether the new documentation requirements might backfire, by reducing the percentage of consumers who are eligible for special enrollment periods who get covered.

Related:

Feds may go after some ‘special’ ACA exchange plan enrollees

Lawmakers’ PPACA exchange looks at special enrollment process

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