How Do We Make Special Enrollment Work?

The third annual Open Enrollment period for the Health Insurance Marketplaces ended on January 31, but enrollment will continue year-round for individuals experiencing certain life or work transitions. Individuals who permanently move, get divorced, lose coverage due to job loss, job change, or an increase in income, or experience other qualifying changes in circumstances are eligible for a time-limited Special Enrollment Period (SEP) in the Marketplaces when their transition occurs.

These enrollment opportunities are a critical part of the health insurance safety net created under the Affordable Care Act (ACA). But the SEP safety net could be weakened if the Centers for Medicare and Medicaid Services (CMS) or Marketplaces take steps that would make it more difficult for individuals to enroll using Special Enrollment Periods, a policy change that insurers are advocating.

Insurers have alleged that SEPs are being misused by consumers, but have not publicly provided data demonstrating misuse. Insurers concerns seem to stem in part from their surprise at the number of SEP enrollees, and those enrollees’ shorter duration of coverage and higher costs compared to those who enroll during Open Enrollment.

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