SEP for "renewing" IFP Plans

Yagents

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Arizona
I know Assurant is allowing this for OFF exchange, now it looks like ON exchange will consider GF and NON GF plans renewing as an SEP also.

http://go.cms.gov/1udRvAx

Special Enrollment Periods for Individuals Whose Individual Market Plans are Renewing Outside of Open Enrollment
45 CFR 147.104(b)(2) provides that a health insurance issuer in the individual market must provide a limited open enrollment period beginning on the date that is 30 calendar days prior to the date the policy year ends in 2014. In the Proposed Rule on Exchange and Insurance Market Standards for 2015 and Beyond, HHS proposed amending 45 CFR 155.420(d)(1) to adopt a special enrollment period for the FFM that is aligned with the limited special enrollment period in 45 CFR 147.104(b)(2). HHS is currently reviewing comments submitted for the Proposed Rule on Exchange and Insurance Market Standards for 2015 and Beyond.
In light of 45 CFR 147.104(b)(2), consumers may have reasonably expected to have an option not to renew non-calendar year individual market policies and to receive a special enrollment period in the FFM outside of the open enrollment period. Therefore, at this time, in accordance with 45 CFR 155.420(d)(9), HHS will provide special enrollment periods consistent with 45 CFR 147.104(b)(2).
Affected individual market consumers will be able to report to the FFM that they will not renew their plan up to 60 days before the renewal date, and can get coverage in the FFM effective the first of the month following the renewal date. Consumers will also have 60 days from the renewal date to select QHPs in the FFM. If a QHP is selected after the renewal date, coverage will be prospective based on the date of plan selection. These individuals should indicate "loss of other coverage" on their Marketplace application, if they would like to apply for and enroll in a QHP offered by the Marketplace plan, if otherwise eligible.
 
I did this for a May 1st effective date. Works like a charm. no proof of any kind required by the marketplace.
 
So...we are going to be able to enter an SEP on 11/1 for all of the existing 12/1 business? Am I reading this correctly?

THIS IS MAJOR NEWS.

We could have our pre-ACA books renewed and happy before OEP starts. That will make life a little easier next OEP.

All of my pre-ACA business renewed 12/1, except for the 2 people I had on disability that were subsidy eligible. :)
 
So...we are going to be able to enter an SEP on 11/1 for all of the existing 12/1 business? Am I reading this correctly?

THIS IS MAJOR NEWS.

We could have our pre-ACA books renewed and happy before OEP starts. That will make life a little easier next OEP.

All of my pre-ACA business renewed 12/1, except for the 2 people I had on disability that were subsidy eligible. :)

It's only great news if we have plans/rates for the 2015 plans at that time. Otherwise, you could find that you have to rewrite the business twice in a matter of two months. A 2014 plan, then a 2015 plan.
 
It's only great news if we have plans/rates for the 2015 plans at that time. Otherwise, you could find that you have to rewrite the business twice in a matter of two months. A 2014 plan, then a 2015 plan.

Texas will (and I only write here). We have to get renewal numbers 60 days out. So I will have 12/1 renewals by 10/1. And 1/1 numbers by 11/1. Even if they are not on the Exchange (and 95% of mine aren't, thank goodness) the numbers should be out there by 11/1 for my 12/1's to compare.

If I "prep" my clients that we want to have decisions made prior to OEP beginning, they will jump on it. An email in September, an email when the renewals are posted, phone appt scheduled the first 2 weeks of November for the decision.

Of course, this assumes we will allow pre-ACA plans to continue to renew. Which I suspect we will. Perry really wants us to keep off ACA if at all possible.
 
I know Assurant is allowing this for OFF exchange, now it looks like ON exchange will consider GF and NON GF plans renewing as an SEP also.

http://go.cms.gov/1udRvAx

Special Enrollment Periods for Individuals Whose Individual Market Plans are Renewing Outside of Open Enrollment
45 CFR 147.104(b)(2) provides that a health insurance issuer in the individual market must provide a limited open enrollment period beginning on the date that is 30 calendar days prior to the date the policy year ends in 2014. In the Proposed Rule on Exchange and Insurance Market Standards for 2015 and Beyond, HHS proposed amending 45 CFR 155.420(d)(1) to adopt a special enrollment period for the FFM that is aligned with the limited special enrollment period in 45 CFR 147.104(b)(2). HHS is currently reviewing comments submitted for the Proposed Rule on Exchange and Insurance Market Standards for 2015 and Beyond.
In light of 45 CFR 147.104(b)(2), consumers may have reasonably expected to have an option not to renew non-calendar year individual market policies and to receive a special enrollment period in the FFM outside of the open enrollment period. Therefore, at this time, in accordance with 45 CFR 155.420(d)(9), HHS will provide special enrollment periods consistent with 45 CFR 147.104(b)(2).
Affected individual market consumers will be able to report to the FFM that they will not renew their plan up to 60 days before the renewal date, and can get coverage in the FFM effective the first of the month following the renewal date. Consumers will also have 60 days from the renewal date to select QHPs in the FFM. If a QHP is selected after the renewal date, coverage will be prospective based on the date of plan selection. These individuals should indicate "loss of other coverage" on their Marketplace application, if they would like to apply for and enroll in a QHP offered by the Marketplace plan, if otherwise eligible.

Does this SEP guideance only apply to plans written " On Exchange".
 
Todd,

It refers to "Individuals Whose Individual Market Plans are Renewing Outside of Open Enrollment", to quote the guidance you quoted in your quote.

(yes, that means on or off exchange, with or without subsidy)
 
What the law states, and what actually happens are two different things.
I have not tried one of these yet on or off exchange.
 
What the law states, and what actually happens are two different things.
I have not tried one of these yet on or off exchange.

Blue Cross of AZ & Health Net of AZ do NOT consider a renewal OUTSIDE OF THE OPEN ENROLLMENT PERIOD to be a SEP for an off exchange plan , However Humana does.
 
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