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Some 2015 Subsidy Applicants Were Dead: GAO

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Officials at the U.S. Government Accountability Office (GAO), an agency that helps Congress keeps tabs on the executive branch of the federal government, have reported that finding in a review of application, enrollment and eligibility-verification operations for the 2015 plan year.

(Related: CMS’ Health Premium Tax Credit Verification Programs Get Failing Grade From IRS)

When GAO investigators looked at records for 8 million people who received federal premium subsidies in 2015, they found that a total of about 19,000 of the subsidy users, or about one in 420 subsidy users, died sometime between filing an exchange application and the end of 2015.

About 16,000 of the subsidy users, or one in 500 of all subsidy users, died in 2015, after their coverage took effect. Another 3,000 died before their coverage took effect.

  • The GAO found it was unable to verify the applications of 307,000 applicants with Social Security Administration death records, because Social Security numbers were missing from the applications or for other reasons.

  • and exchange plan issuers cut off subsidies on the date of death for just 2,000 of the 16,000 2015 subsidy users who died in 2015.

  • About 1,000 people, or about one in 7,700 subsidy users, died between the application date and the coverage start date, and ended up collecting at least some premium subsidy help while they were already dead.

  • About 1,700 people who died in 2014 received at least some subsidy help in 2015 because helped those people re-enroll automatically without checking first to see whether those people were still alive.

  • Some party other than submitted 2015 premium subsidy applications for about 300 people who were already dead before the applications were submitted.

Seto Bagdoyan, a GAO auditor, summarized the results of the investigation for Congress. A copy of his summary is available here. and ACA Subsidies

Congress added the public exchange system provisions to the Affordable Care Act in an effort to create a web-based “Travelocity for health insurance.”

Exchange system supports said the system would help people compare high-quality health insurance policies from commercial insurers on an apples-to-apples basis, and to get the new ACA advance premium tax credit (APTC) premium subsidies.

Originally, states were supposed to set up and run their own exchange programs. (Image: CMS)

(Image: Centers for Medicare and Medicaid Services)

The Centers for Medicare and Medicaid Services, an arm of the U.S. Department of Health and Human Services, created to provide exchange services for residents of states that were unable or unwilling to provide exchange services.

In 2015, provided ACA exchanges services for individual coverage buyers in 37 states.

What Else the GAO Found

ACA critics in Congress have worried about managers’ ability to prevent, detect and respond to fraud.

GAO investigators looked at data for 804,000 enrollees to see how well handled three major types of problems:

  • Apparent conflicts between what applicants said about their immigration status and what a U.S. Department of Homeland Security status verification system shows.

  • Apparent conflicts between the Social Security numbers applicants put on their applications and what Social Security Administration records show.

  • Cases of people using APTC premium subsidy help after the Social Security Administration had received reports of those people being dead.

All of the conflicts the GAO identified are not necessarily examples of fraud or improper receipt of payments.

In some cases, conflicts may have cropped up because APTC applicants made innocent errors on their applications, because the verification databases contained errors, or because the APTC applicants were the victims of identity theft.

But the GAO investigators found that, in October, 2016, a total of about 5% of the 2015 subsidy users still had some kind of unresolved question about immigration status verification, a Social Security number conflict, apparent post-death receipt of subsidy help, or an inability to check the application against Social Security records.

In addition to the 307,000 subsidy users with applications that could not be checked against Social Security records, and the 17,000 who died before or during the plan year without their coverage ending on the date of death, there were 43,000 subsidy users who had unresolved immigration status questions and 33,000 who had unresolved questions about apparent Social Security number conflicts.

Another 33,000 2015 subsidy users, or in 240 of all 2015 subsidy users, still had concerns about Social Security number conflicts associated with their applications in October 2016.

GAO officials suggested that managers could reduce the scope of the problem with post-death receipt of APTC subsidy help by having automatic re-enrollment systems do a better job of checking Social Security death records.

— Read GAO tests ACA exchange special enrollment defenses on ThinkAdvisor.

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