How to Change Plans for On Exchange Clients
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- 1,168
After 1/1/14. Network of doctors wasn't the correct network and is too skinny for the client. Called CMS and had to push and shove the rep there to escalate this to the next step. Hint: Use the terms Special Election Period and client based decision based on Misinformation to get them to escalate the next step.
- 8,448
My esteemed colleagues...I need your interpretation of the last Q&A in the attached document that describes rules for Open and Special Enrollments, as BCBSIL interprets them.
My question: If you enroll in a NON-Subsidized health plan at Healthcare.gov, is that the same thing as enrolling in a "Marketplace health plan"? The Marketplace doesn't even own health plans. It's just the middleman/sugardada.
I ask, because I have a client who enrolled at healthcare.gov without consulting me.(tisk tisk tisk!) Didn't qualify for subsidy due to high income. Out of innocent ignorance, he chose the narrow network BCBSIL plan with no local hospitals. I alerted him to this...we submitted a change form. He had already paid the Jan2014 premium.
His Request for Policy Change has been in "Pending" status since 1/10/2014. BCBS-IL says that they're not processing policy change applications at the moment because they're too busy with "important" stuff, but they'll get around to it. I'm wondering if BCBS will EVER process this client's request to change to the wider network BCBS plan.
If buying a non-subsidized BCBS-IL health plan through HealthCare.gov means that he's purchased a "Marketplace Plan", Stevie is screwed. His medical bills last year were over $200,000 but he was in a BCBS high-risk pool plan that almost every doctor accepts. Now, he's panicking. What is your definition of a Marketplace Health Plan? TIA.
-Allen
My question: If you enroll in a NON-Subsidized health plan at Healthcare.gov, is that the same thing as enrolling in a "Marketplace health plan"? The Marketplace doesn't even own health plans. It's just the middleman/sugardada.
I ask, because I have a client who enrolled at healthcare.gov without consulting me.(tisk tisk tisk!) Didn't qualify for subsidy due to high income. Out of innocent ignorance, he chose the narrow network BCBSIL plan with no local hospitals. I alerted him to this...we submitted a change form. He had already paid the Jan2014 premium.
His Request for Policy Change has been in "Pending" status since 1/10/2014. BCBS-IL says that they're not processing policy change applications at the moment because they're too busy with "important" stuff, but they'll get around to it. I'm wondering if BCBS will EVER process this client's request to change to the wider network BCBS plan.
If buying a non-subsidized BCBS-IL health plan through HealthCare.gov means that he's purchased a "Marketplace Plan", Stevie is screwed. His medical bills last year were over $200,000 but he was in a BCBS high-risk pool plan that almost every doctor accepts. Now, he's panicking. What is your definition of a Marketplace Health Plan? TIA.
-Allen
Q If an individual who previously selected a plan wants to switch
plans, is that an option through March 31, 2014?
A If an individual enrolled in an off-Marketplace plan, the individual can
switch to a new plan during open enrollment. The individual would
need to submit a new application to make a new plan choice.
If an individual enrolled in a plan via the Marketplace, plan changes are
not allowed after the member has paid or after the effective date of the
policy. Once a member pays his first month's premium, he will not be
able to cancel his policy until the end of the first coverage month. If a
member cancels his on-Marketplace plan, either voluntarily or due to
non-payment, he will not be able to enroll in another Marketplace plan
unless he qualifies for a Special Enrollment Period or do so during the
next open enrollment.
However, if the individual wants to cancel the Marketplace plan during
open enrollment and enroll off-Marketplace, he could, but again, he
would not receive a premium tax credit and cost-sharing assistance.
plans, is that an option through March 31, 2014?
A If an individual enrolled in an off-Marketplace plan, the individual can
switch to a new plan during open enrollment. The individual would
need to submit a new application to make a new plan choice.
If an individual enrolled in a plan via the Marketplace, plan changes are
not allowed after the member has paid or after the effective date of the
policy. Once a member pays his first month's premium, he will not be
able to cancel his policy until the end of the first coverage month. If a
member cancels his on-Marketplace plan, either voluntarily or due to
non-payment, he will not be able to enroll in another Marketplace plan
unless he qualifies for a Special Enrollment Period or do so during the
next open enrollment.
However, if the individual wants to cancel the Marketplace plan during
open enrollment and enroll off-Marketplace, he could, but again, he
would not receive a premium tax credit and cost-sharing assistance.
He's toast.... Just like I told you all back a year agon, as per mapd and part d rules, once the policy effective date comes the changing game is over.... Listen next time
- 8,448
Thanks for the feedback Tim and Lisa. Let me get this straight. Even though the client purchased a Blue Cross plan, because he did so via healthcare.gov, the policy is an Exchange plan.
He CAN change to a different plan (same or not the same company) without a gap in coverage, but he can only do so if he has NOT paid a premium yet.
Even though the January premium has been paid, hopefully Blue Cross of IL is allowing Stevie to change to a better plan, because the company hasn't rejected the application. Instead, they're just saying that processing it isn't a top priority right now. Since many thousands of people in this state mistakenly chose the narrow network plan because BCBS-IL didn't disclose that it wasn't suitable for their geographic location, the company may be granting an exception. Lots of other exceptions have been implemented/granted, so hopefully this will just be another one. Thanks again!
-Allen
He CAN change to a different plan (same or not the same company) without a gap in coverage, but he can only do so if he has NOT paid a premium yet.
Even though the January premium has been paid, hopefully Blue Cross of IL is allowing Stevie to change to a better plan, because the company hasn't rejected the application. Instead, they're just saying that processing it isn't a top priority right now. Since many thousands of people in this state mistakenly chose the narrow network plan because BCBS-IL didn't disclose that it wasn't suitable for their geographic location, the company may be granting an exception. Lots of other exceptions have been implemented/granted, so hopefully this will just be another one. Thanks again!
-Allen
______________________________________________________________
Correct-if he enrolled through the Marketplace, he has enrolled in an ON Exchange plan. If enrolled in an ON Exchange plan, if he has paid his first premium, he can cancel the plan at the end of the month as long as during Open Enrollment; however, he would not be eligible to enroll in another ON Exchange plan until OE for a 2015 effective date or, if eligible for a SE at any time, he could enroll. Alternatively, he could enroll in an OFF Exchange plan at any time during OE but would not receive any Tax Credit or Subsidy if otherwise eligible.
At least this is how this works today. Stay tuned though as everything is changing daily. Once Sebelius and Obama get wind of this, they will make a televised announcement this is cruel, unusual and discriminatory of the carriers and will mandate them to allow everyone to make changes whenever it is most convenient for them. (I apologize for the sarcasm, though not far from the truth.)
- 8,448
OK..then this is how we'll handle this. Since Stevie is paid up to the end of February with his existing BCBS-IL plan, he will enroll in the desired BCBS-IL plan at the www.bcbsil.com website before Feb 15th, which will give him a March 1st effective date. BCBS will cancel the existing plan at the end of this month and report this to the marketplace.
The only potential downside would be if his 2014 income comes in under 400% of FPL. (He's a small biz owner - car wash/oil change center). By purchasing off-exchange, Stevie will forfeit the ability to claim the APTC should this occur. If he's willing to take the risk associated with this unlikely occurrence, we'll pursue this purchase/cancel approach.
-ac
The only potential downside would be if his 2014 income comes in under 400% of FPL. (He's a small biz owner - car wash/oil change center). By purchasing off-exchange, Stevie will forfeit the ability to claim the APTC should this occur. If he's willing to take the risk associated with this unlikely occurrence, we'll pursue this purchase/cancel approach.
-ac
https://www.healthcare.gov/what-if-i-want-to-change-marketplace-plans-after-i-enroll/
Just some extra supporting evidence, HC.gov says basically the same thing as AC's BCBS link.
That said, I'm positive I moved a subsidized client after they went to use it and realized what they had (though, a state exchange, not FFM). Also positive it let me apply a subsidy (and a different subsidy than the first plan). Our exchange's rep gave me the procedure and it all appeared to go through fine.
Maybe what you're "allowed" to do and "can" do are two different things. Wouldn't be surprised if they never programmed in a feature denying you subsidy if you change plans during OEP.
Just some extra supporting evidence, HC.gov says basically the same thing as AC's BCBS link.
That said, I'm positive I moved a subsidized client after they went to use it and realized what they had (though, a state exchange, not FFM). Also positive it let me apply a subsidy (and a different subsidy than the first plan). Our exchange's rep gave me the procedure and it all appeared to go through fine.
Maybe what you're "allowed" to do and "can" do are two different things. Wouldn't be surprised if they never programmed in a feature denying you subsidy if you change plans during OEP.
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