Many health insurance agents are telling the Trump administration that one little well-intended Affordable Care Act procedure change could wreck their lives next fall.

The agents have sent comments to the Centers for Medicare & Medicaid Services to object to a proposal to have the open enrollment period for commercial individual major medical coverage for 2018 start Nov. 1 and end Dec. 15.

Related: ACA exchange team hopes to delay filing dates

The Trump administration and Republicans hope to repeal and replace the ACA. They have not talked in detail about what they want to do with the ACA exchange system or the individual major medical market. Even if they make big changes in the market, they might put off the application date of the changes until after 2018.

Current regulations call for the open enrollment period for 2018 to start Nov. 1, 2017, and end Jan. 31, 2017.

Regulators, insurers and ACA public exchange managers set up the open enrollment period system, or limits on when people have an easy time buying health coverage, to give insurers to protect against claim risk.

Before Jan. 1, 2014, insurers could protect themselves by turning away sick people. If new enrollees had known health problems, insurers could exclude those problems from the coverage for a few months. Insurers could also impose annual and lifetime benefits payment limits.

The ACA eliminated all of those defenses.

In exchange, the ACA provided new premium subsidies, to help healthy people pay for coverage, and an individual coverage ownership mandate, to push healthy people to pay for coverage.

The open enrollment period system is supposed to supplement those ACA provisions, by discouraging healthy people from intentionally waiting until they get sick to pay for coverage. The system is supposed to leave healthy people with the fear that, if they wait to pay for coverage, they may get sick and run up huge bills at a time of the year when they cannot get coverage.

To buy health coverage outside the open enrollment period, consumers must show they have what the government thinks of as a good excuse to apply for coverage through a special enrollment period.

The Medicare Advantage program has a similar annual election period. The Medicare plan annual election period always runs from Oct. 15 through Dec. 7.

Insurers, and regulators, believe that making the ACA individual major medical open enrollment period shorter will make the system a more powerful defense against “free riders.”

A shorter open enrollment period is part of a package of proposals CMS officials developed in an effort to persuade insurers to sell individual major medical coverage in 2018.

Comments on the proposal aren’t due until March 7, but many insurance agents have already sent in letters. CMS officials are supposed to review comments before they complete work on proposed regulations.

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In some of the letters, agents acknowledge that a shorter open enrollment period could help insurers reduce free-rider risk.

The agents say the change could also make their lives miserable. Here’s a look at five of the agents’ concerns about the proposed change.

Some agents say the proposed enrollment period change makes compensation cuts more painful. (Image: Thinkstock)

Some agents say the proposed enrollment period change makes compensation cuts more painful. (Image: Thinkstock)

1. Money

Mark Soderstrom, an agent, pointed out that the agents trying to help consumers sign up for coverage are already facing a terrible drop in compensation, and that the new proposal does nothing to help agents with that problem.

In Oregon, he writes, agents earn about $400 per year for each Medicare supplement or Medicare Advantage policy they write, but only about $144 per year in commissions for selling an individual policy through the ACA public exchange system.

Marcus Campbell, a North Carolina agent, says the low compensation level hurts consumers, by reducing their access to licensed professionals who can help them choose and understand coverage.

He would like to see regulators set and enforce commission payment standards, and possibly for the system to provide grants for agencies that agree to run year-round problem-solving walk-in shops.

Related: The DOL fiduciary rule: reactions from 4 industry associations 

The new health market conditions make hiring and training good assistants difficult, agents say. (Photo: Thinkstock)

The new health market conditions make hiring and training good assistants difficult, agents say. (Photo: Thinkstock)

2. Human resources

Susan McWright of Kentucky says one problem with shortening the individual major medical open enrollment period when individual policy sales compensation is so low is that cash-strapped agents have no way to hire extra people to help them with an accelerated process.

McWright, who has been selling ACA exchange plan coverage through three open enrollment periods, says many consumers definitely need one-on-one assistance.

“Many do not have computers, and a significant number have language barriers which makes it difficult for them to call in,” McWright says. “Some have no experience with our concept of health insurance and require a lot of education to understand their policy.”

Daryl Schafer, a Pennsylvania agent, says offering a longer open enrollment period, or at least eliminating most of the overlap with the Medicare annual election period, would also make it easier for insurers hire long-term customer support employees with adequate training.

Related: The DOL fiduciary rule: reactions from 4 industry associations 

Agents say a 45-day open enrollment period will probably mean they have to work 20 hours per day on most of those days. (Photo: Thinkstock)

Agents say a 45-day open enrollment period will probably mean they have to work 20 hours per day on most of those days. (Photo: Thinkstock)

3. Sleep

Maria Overcash of South Carolina predicted that shortening the open enrollment period to 45 days, from 92 days, will mean that she and colleagues will have to work 20 hours per day for 45 straight days.

“This is not only unfair to us, it also is extremely unfair to the average person needing help because they have a very hard time finding someone to help them who knows what they are doing,” Overcash writes. “I want to know why people processing taxes are allowed 2 and half months to do their jobs and we only get 1.5 months to do ours.”

Related: Provider network storm gains strength 

Agents say the proposed 2018 open enrollment period would kill their Thanksgiving holidays. (Photo: Thinkstock)

Agents say the proposed 2018 open enrollment period would kill their Thanksgiving holidays. (Photo: Thinkstock)

4. Thanksgiving

Some agents pointed out that, if the open enrollment period runs from Nov. 1 through Dec. 15, that means that they will be working 20-hour days even over Thanksgiving, or work more than 20 hours per day on some other days to make up for time lost to Thanksgiving. 

Related: What agent groups hate about proposed 2017 PPACA World rules 

Agents say running a short individual commercial markt open enrollment period alongside the Medicare election period will force them to help Medicare clients first. (Photo: Thinkstock)

Agents say running a short individual commercial market open enrollment period alongside the Medicare election period will force them to help Medicare clients first. (Photo: Thinkstock)

5. Medicare

Michelle Thomas of Oregon writes that, given how the markets work, shortening the ACA open enrollment period and running it mostly alongside the Medicare plan election period would force many agents to focus on working with the Medicare clients and leaving the ACA clients to fend for themselves.

“For the computer-challenged and/or older clients, this would be an undue burden,” Thomas writes.

Related:

3 flares from the short-term health firefight

5 hot battles over the PPACA-free zone

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