It's almost game day for the second season of ACA insurance exchanges, and insurers need to get ready to handle all sorts of consumer inquiries and administrative tasks.
The Centers for Medicare & Medicaid Services is hoping to avoid another technology flop with the HealthCare.gov marketplace. Regulators say they're ready to work with health plans to re-enroll millions of buyers from last year and sign up millions of new ones.
CMS has set an early October launch for the visual redesign of HealthCare.gov's navigational section for returning enrollees, and notices from the exchange will go out October 15, a month before renewal notices from insurers.
The federal marketplace, serving consumers in more than 30 states, will be sending enrolled exchange members letters and a series of email reminders ahead of open enrollment, as well as sponsoring multimedia outreach and promoting help over the phone via call centers.
The exchange's outreach and support, along with help from health plans and enrollment assister, may not necessarily ensure a smooth consumer experience, given the technology involved and the complexity of individual cases.
In the presentation, CMS outlined four likely scenarios that insurers and enrollment assisters are likely to see. One is an enrollee who authorized the exchange to gather updated tax return data, and who is automatically enrolled with the 2014 advanced premium tax credit and cost-sharing levels. Another is an enrollee who updates an application and selects a new plan for 2015, and receives subsidies at the 2015 federal poverty level rates, adjusted for inflation from the previous year.
A third scenario is a consumer who does not provide access to updated tax return information and who does not return to the exchange to update their data; a fourth is those who got a new job or a substantial income raise that brings them beyond 400 percent of the federal poverty level and leaves them no longer eligible for subsidies.
Exchange plans can hope that many of the re-enrollment cases will be consumers who update their financial information and see only minor tweaks in their tax credits for 2015 and their premium obligations. Those consumers will have the choice to stay with their previous plan or choose a new one.
The more complex and vexing cases will be those where consumers take no action.
One scenario, as outlined by CMS, is Jane, a returning customer, but with a significant change in income:
She applied through the Marketplace on 3/12/2014. She authorized the Marketplace to access her updated tax data for purposes of annual redetermination. Her household income and family size made her eligible for APTC at 325% FPL. She enrolled in a plan with a 4/1/2014 effective date and is current on premiums.
When the Marketplace looked at Jane's updated tax return, it reflected her most recent household income as 600% FPL (based on her 2013 tax return). Her Marketplace notice includes both the general information and the tailored information for enrollees who will not continue to receive APTC/CSR for their 2015 coverage if they take no action. Her insurance company sent her a notice informing her that her coverage is available for 2015 without change.
She does not contact the Marketplace to provide updated information. On December 15, 2014, her coverage is automatically renewed, effective 1/1/2015, without APTC or CSR.
Some of the onus for a smooth re-enrollment falls on insurers to meet the November 15 deadline for email or letter notifications of renewal (or plan discontinuation) and then to make sure all of the exchange members take action some time during open enrollment.
"Consumers should use both their notices – from the issuer and from the Marketplace – to make sure they make the most informed decision during the annual open enrollment process," regulators wrote.