Insurers and consumer advocates are facing off over a Department of Health and Human Services proposal to extend the Affordable Care Actâs annual enrollment period and allow year-round sign-ups for those with low incomes.
In public comment letters on the proposed update (RIN 0938âAU60) of Obamacare benefits and payment parameters, major marketplace insurers like Anthem, Centene Corp., and UnitedHealthcare, all opposed a plan to lengthen the federal open enrollment period from 45 days to 75 days.
The longer enrollment would allow people who âwere automatically re-enrolled into a plan to reevaluate their options after receiving updated plan cost information in the new year and select a new plan that is more affordable,â Fred Riccardi, president of the Medicare Rights Center, said in a comment letter.
But insurer Molina Healthcare said the proposal âcreates the potential of adverse selection as healthier members could defer enrollment until the last minute and unhealthier members would enroll earlier, which would increase costs and premiums,â Carolyn Ingram, Molinaâs executive vice president for external affairs, said.
If finalized by the Centers for Medicare & Medicaid Services, the annual sign-up period would run from Nov. 1 to Jan. 15. It now ends Dec. 15.
Instead of a longer enrollment period, Americaâs Health Insurance Plans recommends that the CMS establish a targeted special enrollment period for those âwho automatically reenroll and experience an increase in premium. The end of the open enrollment period, December 15, should be the triggering event for a 30-day special enrollment period with prospective effective dates,â AHIPâs comment letter said.
Special Enrollment
The industry also opposes a CMS plan for a new monthly special enrollment period for adults and dependents who are eligible for advance premium tax creditsâand whose household income is less than 150% of the federal poverty level. It would allow them to enroll in marketplace coverage whenever their income or eligibility permits. They now must experience a qualifying life event or wait for the annual open enrollment period to get coverage.
Riccardi and Pennsylvania Insurance Commissioner Jessica Altman both support the CMSâs special enrollment proposal. Itâs designed to help people who lose Medicaid coverage, a population thatâs sure to increase when the pandemic health emergency is lifted.
The special sign-up period would allow âPennsylvanians to ensure that those losing Medicaid coverage have access to quality, affordable health coverage and care throughout the marketplace,â Altman wrote in her comment letter.
AHIP says that can be done through enhanced noticing and special outreach that encourages people to maintain continuous coverage.
If people could enroll at any time, or change plan selections each month, âwe anticipate consumers would enroll in coverage at the point of care and or change plans mid-year. Constant enrollments and disenrollments would undermine stability of the individual market and could result in higher premiums, narrower networks, and limit consumer choice,â Jeanette Thornton, AHIPâs senior vice president for product, employer, and commercial policy, said in her letter.
Standardized Plans
Anthem, which covers nearly 700,000 people in the individual market, said in its comment letter that the current 45-day enrollment period should continue. But if the CMS does make changes, it would prefer a longer annual enrollment period over the proposed special enrollment period.
If the CMS does extend the enrollment period, Anthem recommends that applications submitted by Dec. 15 have a Jan. 1 effective date. And those submitted between Dec. 16 and Jan. 15 take effect Feb. 1. As written, the current proposal doesnât provide effective dates.
Insurers also donât want the CMS to require them to offer standardized plan options thatare designed to make it easier for consumers to compare and shop for coverage. The CMS plans to resume standardized plan options in 2023 after a federal court overturned a Trump administration rule that scrapped the practice of designating some plans as âstandardized options.â The agency will also propose standardized plan designs for 2023.
UnitedHealthCare recommended that CMS permit, rather than require standardized plan options to give issuers âthe latitude to continue pursuing innovative offerings.â
Roughly 40 organizations representing patients with complex conditions like autoimmune diseases, HIV, and hepatitis, want the CMS to require federal marketplace insurers to offer some standardized plans that either cap cost-sharing for prescription drugs and require no co-pay or deductible. In a joint comment letter, the groups say the federal government should follow states like California, Delaware, Louisiana, and Maryland, as well as the District of Columbia âthat cap the amount a patient must pay out-of-pocket for a one-month supply of a single prescription medication.â
AHIP says insurers shouldnât be required to offer the plans and that the CMS should not âimplement differential display of standardized plan options on Healthcare.govâ nor âgive special preference to these plans.â
âWe are concerned that a differential display would increase consumer confusion and may appear to favor some plans over others and inadvertently steer consumers or otherwise influence the shopping experience,â AHIPâs comment letter said.
To contact the reporter on this story: Tony Pugh in Washington at tpugh@bloomberglaw.com
Health Insurers, Advocates Clash Over Proposed Obamacare Updates
Bloomberg
August 6, 2021 9:09 pm
Insurers and consumer advocates are facing off over a Department of Health and Human Services proposal to extend the Affordable Care Actâs annual enrollment period and allow year-round sign-ups for those with low incomes.
In public comment letters on the proposed update (RIN 0938âAU60) of Obamacare benefits and payment parameters, major marketplace insurers like Anthem, Centene Corp., and UnitedHealthcare, all opposed a plan to lengthen the federal open enrollment period from 45 days to 75 days.
The longer enrollment would allow people who âwere automatically re-enrolled into a plan to reevaluate their options after receiving updated plan cost information in the new year and select a new plan that is more affordable,â Fred Riccardi, president of the Medicare Rights Center, said in a comment letter.
But insurer Molina Healthcare said the proposal âcreates the potential of adverse selection as healthier members could defer enrollment until the last minute and unhealthier members would enroll earlier, which would increase costs and premiums,â Carolyn Ingram, Molinaâs executive vice president for external affairs, said.
If finalized by the Centers for Medicare & Medicaid Services, the annual sign-up period would run from Nov. 1 to Jan. 15. It now ends Dec. 15.
Instead of a longer enrollment period, Americaâs Health Insurance Plans recommends that the CMS establish a targeted special enrollment period for those âwho automatically reenroll and experience an increase in premium. The end of the open enrollment period, December 15, should be the triggering event for a 30-day special enrollment period with prospective effective dates,â AHIPâs comment letter said.
Special Enrollment
The industry also opposes a CMS plan for a new monthly special enrollment period for adults and dependents who are eligible for advance premium tax creditsâand whose household income is less than 150% of the federal poverty level. It would allow them to enroll in marketplace coverage whenever their income or eligibility permits. They now must experience a qualifying life event or wait for the annual open enrollment period to get coverage.
Riccardi and Pennsylvania Insurance Commissioner Jessica Altman both support the CMSâs special enrollment proposal. Itâs designed to help people who lose Medicaid coverage, a population thatâs sure to increase when the pandemic health emergency is lifted.
The special sign-up period would allow âPennsylvanians to ensure that those losing Medicaid coverage have access to quality, affordable health coverage and care throughout the marketplace,â Altman wrote in her comment letter.
AHIP says that can be done through enhanced noticing and special outreach that encourages people to maintain continuous coverage.
If people could enroll at any time, or change plan selections each month, âwe anticipate consumers would enroll in coverage at the point of care and or change plans mid-year. Constant enrollments and disenrollments would undermine stability of the individual market and could result in higher premiums, narrower networks, and limit consumer choice,â Jeanette Thornton, AHIPâs senior vice president for product, employer, and commercial policy, said in her letter.
Standardized Plans
Anthem, which covers nearly 700,000 people in the individual market, said in its comment letter that the current 45-day enrollment period should continue. But if the CMS does make changes, it would prefer a longer annual enrollment period over the proposed special enrollment period.
If the CMS does extend the enrollment period, Anthem recommends that applications submitted by Dec. 15 have a Jan. 1 effective date. And those submitted between Dec. 16 and Jan. 15 take effect Feb. 1. As written, the current proposal doesnât provide effective dates.
Insurers also donât want the CMS to require them to offer standardized plan options thatare designed to make it easier for consumers to compare and shop for coverage. The CMS plans to resume standardized plan options in 2023 after a federal court overturned a Trump administration rule that scrapped the practice of designating some plans as âstandardized options.â The agency will also propose standardized plan designs for 2023.
UnitedHealthCare recommended that CMS permit, rather than require standardized plan options to give issuers âthe latitude to continue pursuing innovative offerings.â
Roughly 40 organizations representing patients with complex conditions like autoimmune diseases, HIV, and hepatitis, want the CMS to require federal marketplace insurers to offer some standardized plans that either cap cost-sharing for prescription drugs and require no co-pay or deductible. In a joint comment letter, the groups say the federal government should follow states like California, Delaware, Louisiana, and Maryland, as well as the District of Columbia âthat cap the amount a patient must pay out-of-pocket for a one-month supply of a single prescription medication.â
AHIP says insurers shouldnât be required to offer the plans and that the CMS should not âimplement differential display of standardized plan options on Healthcare.govâ nor âgive special preference to these plans.â
âWe are concerned that a differential display would increase consumer confusion and may appear to favor some plans over others and inadvertently steer consumers or otherwise influence the shopping experience,â AHIPâs comment letter said.
To contact the reporter on this story: Tony Pugh in Washington at tpugh@bloomberglaw.com