Address Change / SEP Proof?

[Yagents]

Double the work:

https://www.regtap.info/faq_viewe.php?i=4935

Don't need no stinkin' proof:

https://www.regtap.info/faq_viewe.php?i=4936

 

[Professor Leads]

That is interesting.

I know of quite a few people whom have been cancelled by their insurer after enrolling through the FFM because of an address issue. This tells me they can not do that.

 

[RayNY]

RVerHI, could you explain or elaborate?

The first one says that a carrier cannot deny an SEP sent through the marketplace, the second one says they are allowed to change an address (that does not change eligibility) if the request comes from HICS or the consumer direct, and an 834 is not required in this situation.

Nothing implies they can't cancel due to incorrect data. Even if the SEP is valid, if you're out of the service area, or being billed to the wrong address and not paying, they can term you.

 

[Professor Leads]

Sorry so late on this...

My clients are a unique group. They are mostly fulltime RVers. Their RV is their home with no other stick-n-brick home. They establish residency in a state by registering vehicles, obtaining drivers license, and having a mail-forwarding service handle their address and mail.

Many carriers are saying that if they find out the members does not have an actual physical address with utility bill in that state they will deny/cancel coverage after receiving their enrollment from ACA.

I know this is not specifically SEP-related but many times these people 'move' (meaning become fulltime RVers and establish residency in another state) in the middle of summer to so they use a SEP to enroll.

 

[RayNY]

RVerHI, sounds like your unique groups gets to face some unique challenges complying with the mandate. If they are true nomads, with no "home base", expect them to get kicked off regularly as the carrier finds out. Termination isn't an SEP event, so once they're caught, they might be stuck until OEP.

I know trailer parks, with dedicated lot addresses (and the electric/gas hookup that comes with that), are respected as residences by carriers. Parking by the beach this week, the forest next week, and maybe a different state or country after that? That's not going to fly.

 

[Professor Leads]

Yes, but that beach or forest is not their residence state. Their legal residency is where they: vote, pay taxes, register vehicles, and have DL. They just don't spend all their time in that state.

Seems to me that the insurance company still has to insure them if the marketplace verifies identity and residency in a state. This is what I have been told when calling the marketplace as well. Still, it has not stopped the insurance company from dropping those that can't provide a utility bill. And, yes, several I know of have been stuck without coverage because they were dropped outside of OE.

If an insurer is offering marketplace plans then the eligibility should be based on marketplace rules...which do not ask for utility bill.

 

[AllenChicago]

which insurer is trying to pull this crap? on a related note, people whose lives are transient in nature need to make sure that they get in the widest ppo network possible

 

[Professor Leads]

which insurer is trying to pull this crap? on a related note, people whose lives are transient in nature need to make sure that they get in the widest ppo network possible

All 3 carriers on the exchange in SD are doing this now: DakotaCare, Sanford, and Avera.

 

[AllenChicago]

All 3 carriers on the exchange in SD are doing this now: DakotaCare, Sanford, and Avera.

Whoah..they're really playing with fire then. Or perhaps the Exchange/HHS needs THEM more than THEY need the EXCHANGE/HHS.

 

[RayNY]

Yes, but that beach or forest is not their residence state. Their legal residency is where they: vote, pay taxes, register vehicles, and have DL. They just don't spend all their time in that state.

Seems to me that the insurance company still has to insure them if the marketplace verifies identity and residency in a state.

If an insurer is offering marketplace plans then the eligibility should be based on marketplace rules...which do not ask for utility bill.

The carrier did insure them, as per your story. Carriers have the right to verify information, regardless of the submission source, and to terminate coverage for false information. Managing to trick the exchange does not give a free pass from this process. Over 1 million on-exchange applicants had to prove residency, and over 300,000 were unable to. Your client is by no means alone.

I'd encourage you to check the legal definitions, with a lawyer friend if necessary. It sounds to me like you have proven a domicile state, but not a permanent residence address. A permanent residence (legal residence) is a specific location, not a state.