After Open Enrollment:

3-10-2014

I read at KaiserHealthNews.org today that if an applicant purchased a health plan outside of Open Enrollment due to an event triggering a Special Enrollment Period (SEP), he/she will have to pick a new plan, or re-enroll in the same plan during the next Open Enrollment. The reason given is to align this person with the annual O.E. going forward. Does this sound right/accurate?
ac
 
Allen,

I've heard the same thing from a few sources-but no legal documentation was cited. I've also heard it a step further-ALL business will renew on Jan 1, and the only time to make changes is during the OEP next year. Again, nothing was cited.

That said, I just talked with a supervisor at my state's Exchange Support line. She confirmed (3 times!) the following:
-SEP plans are 12-month contracts, they DO NOT renew Jan 1.
-SEP clients WILL NOT be forced to renew during OEP
-Expiration of an existing QHP contract (not termination for cause, cancellation, or rescission) generates a new SEP.
-Because it generates a new SEP, the client may renew, or change plans, within the 60-day window a defined by law.

(Expiration of a QHP contract is not explicitly given as one of the 9 SEP generating situations according to federal guidance. The solution is applying "loss of minimum essential coverage" to this scenario, as advised by the exchange representative.)
 
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