Exit Actions and Their Effective Date?

[RayNY]

Moral of the story, for qualifying events that involve a "no fault loss of coverage", the new plan goes into effect the 1st day of the next month, regardless of application date. (Marriage has the same rule.)

4/30 term? Apply by 6/30 for a 5/1 effective (of course, back premium is due! There is no choice, clients can't choose an effective date, and can't choose to have a lapse, even if they want to.).

I've confirmed this with our state's exchange (click here for a webinar reiterating it, see page 13), carriers, and even wrote a 4/1 policy last week using a 3/31 QE, and it's been approved.

(FYI, this is drastically different than what the CSR's at our exchange told me, repeatedly, for months. I understand if you doubt this claim.)

I recognize my information is NY-specific, but the federal law's text has the same guidelines.
To quote 45 CFR 155.420 (b):
"(2) Special effective dates.
(i) In the case of birth, adoption or placement for adoption, the Exchange must ensure that coverage is effective on the date of birth, adoption, or placement for adoption, but advance payments of the premium tax credit and cost-sharing reductions, if applicable, are not effective until the first day of the following month, unless the birth, adoption, or placement for adoption occurs on the first day of the month; and
(ii) In the case of marriage, or in the case where a qualified individual loses minimum essential coverage, as described in paragraph (d)(1) of this section, the Exchange must ensure coverage is effective on the first day of the following month."

No if/and/but. Must be effective the 1st day of the month following the QE.

 

[houcoogster]

This is true had a kid denied chip the whole family got an 4-1 effective the deal was written about 3-25. I thought at first it was a computer glitch but no it showed up in my agent portal that way.

 

[yorkriver1]

Thanks for examples. Really helpful.

 

[RayNY]

You're welcome, glad I could help!

Houcoogster, thanks for the confirmation.

Honestly, I didn't believe it until my client rec'd approval. Between that, the law, and the guidance, I'm pretty positive that this will be the experience for everyone moving forward. This should alleviate many of the fears we had for our clients who actually need continuous coverage.

 

[G.Gordon]

So far my two life event cases are the same result. The marketplace shows active, the plan when contacted shows active, the doctor's office and pharmacy when they try to access member plan info or fill a prescription, CANCELLED as of the day the life event was presented to the plan.

From now on life events will be presented to the marketplace the day the "change" should take place.