Additional Qualifying Life Event Recently Announced

[mariemerganser]

Got this from one of my carriers last night. Does anyone know anything about this?

"For the rest of 2014, whenever a grandfathered or non-grandfathered plan renews, it will be a qualifying life event. This event creates added opportunities to continue selling throughout the year, as do other qualifying life events such as when customers are moved to a metallic plan due to health care reform requirements."

 

[VolAgent]

That would be the exact opposite from the DOI here. They put out a memo warning people that when their plan renews this year, they may not be able to apply for new coverage.

 

[RayNY]

It was my understanding that a no-fault discontinuation of current coverage (like an anniversary) is a qualifying event.

I mean, it's literally the first QE under law: "(1) A qualified individual or dependent loses minimum essential coverage; "

Remember, when you "renew", you are not "extending" your plan, you are re-purchasing the new version of the same plan (at a new rate).

Just like you can put your old plate on a new car, keeping an ID number doesn't mean it's not a new plan.

Contract ends, policy ends, MEC has been lost. The availability of renewal options is irrelevant, its a QE.

VolAgent, I presume they're saying "may" to cover their butts because they don't exactly know what's going on. I'd love to see the memo if you have a copy.

 

[VolAgent]

http://www.tn.gov/insurance/documents/memo031714.pdf

It seems "may" was said more because there may not be coverage available, not because they think their understanding was wrong.

It seems other threads suggest that it may be up to the carrier to decide whether there is a SEP or not. So the carriers may still allow enrolling unless the state explicitly tells them no. Based on this memo, it doesn't seem the DOI is going to decide for anyone.

 

[bluediamond]

Got this from one of my carriers last night. Does anyone know anything about this?

"For the rest of 2014, whenever a grandfathered or non-grandfathered plan renews, it will be a qualifying life event. This event creates added opportunities to continue selling throughout the year, as do other qualifying life events such as when customers are moved to a metallic plan due to health care reform requirements."

If it's from FB, yes it's true, plus you can write anyone with a pre-ACA plan from FB off marketplace anytime during the year. Pre ACA being defined plans sold and effective prior to Jan 1, 2014.

 

[Yagents]

This email was from Assurant. Nice to know about FB, did not know that. Any other carriers in FL besides Assurant with liberal SEP's?

 

[bluediamond]

Haven't heard of any, but that doesn't mean that they're not.

 

[RayNY]

VolAgent, thanks for posting that.

It mentions that those who have a GF plan renewal "may have few coverage options" (as in, options to choose from), but nowhere does it say anything about the ability to apply or non-generation of an SEP.

I stand by my prior statement, renewal is a QE, you get an SEP, and can move anywhere you want.

 

[VolAgent]

VolAgent, thanks for posting that.

It mentions that those who have a GF plan renewal "may have few coverage options" (as in, options to choose from), but nowhere does it say anything about the ability to apply or non-generation of an SEP.

I stand by my prior statement, renewal is a QE, you get an SEP, and can move anywhere you want.

Read it again. It says consumers who choose to terminate health coverage because a premium increase makes coverage unaffordable will not be considered to have experienced a loss of coverage for purposes of qualifying for a special enrollment period.

Bold and italics are from the original memo. Based on that, I would say the DOI does not believe a renewal is a QE. It further goes on to state that unaffordable premiums may qualify a consumer for a hardship exemption from the individual mandate. I would say that further emphasizes their position that people will be SOL if they get priced out at renewal. I would say the only reason they used the words "may not" versus "will not" is that they are not sure if insurers will allow enrollments outside of open enrollment.

There really is no reason to write the memo this way if they believe renewal will generate a QE. If that was the DOI's position, it would have emphasized that it does create one and a consumer should act quickly during that period.

 

[RayNY]

Read it again. It says consumers who choose to terminate health coverage because a premium increase makes coverage unaffordable will not be considered to have experienced a loss of coverage] for purposes of qualifying for a special enrollment period.

Voluntary termination is not an SEP. We've been over this many times, the law and guidance explicitly states this.

To cite the law again (same section as last time, 45 CFR 155.420) "Loss of coverage does not include termination or loss due to...[failure to pay or rescission for cause(paraphrased)]"

Renewal is a QE. The law says so. Guidance says so. Examples on the exchange say so. Carriers all say so. My exchange reps say so. I will stand by this statement.

Termination is not. No debate there.