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July/August 2014 St@teside

Buyer Beware? The Potential Challenges of Renewals in the Next Open Enrollment

As Marketplaces gear up for the next fast-approaching open enrollment period, they are facing the challenge of ensuring continuous coverage for their consumers, while protecting them from tax liabilities and avoidable premium increases. Many Marketplaces are considering auto-renewals to ensure that consumers are not dropped from coverage in 2015, and recent federal guidance has also given Marketplaces the flexibility to roll over 2014 Advanced Premium Tax Credits (APTCs) into 2015.

Consumers will benefit from shopping for different plans during the upcoming enrollment period as opposed to auto-renewing or choosing to keep their current 2014 plan without reviewing their options. Changes in the 2015 premium rates could result in changes in the benchmark Silver plan, which is the plan used to determine the amount of APTC an individual receives. If the benchmark plan premium decreases, the APTC amount will decrease as well. Thus, if an enrollee stays in his/her 2014 plan, he/she may end up having to contribute more to the monthly premium in 2015 due to a decrease in APTC. However, there may be less expensive plans available to them in the Marketplace. For a more in-depth look at this issue, check out this white paper, prepared by Wakely Consulting Group with support from the State Health Reform Assistance Network (State Network), "Addressing the Financial Impact of Renewals: Why Many Enrollees Could Benefit from Shopping."

Additionally, the State Network recently convened state officials and technical experts to discuss strategies for confronting this and other potential issues related to the renewals process. The agenda and presentations/resources from the meeting are available on the State Network’s website. Selected materials are also detailed below.

Summary of Redetermination and Coverage Renewal Regulations

This document provides a summary of the proposed regulation and guidance released related to the annual redetermination of eligibility, renewal and re-enrollment in consumers’ Marketplace coverage. The new proposed regulation and associated guidance expands on the re-enrollment process detailed in existing regulations, offering Marketplaces two new alternative approaches for annual eligibility redeterminations, and adds guidelines for re-enrolling consumers in coverage. This summary also examines the recently released federal standard issuer notices and implementation instructions for the renewal or discontinuance of individual and small group coverage on and off the Marketplace.

Eligibility and Enrollment Processes

This presentation walks through the eligibility and enrollment process flows, identifying policy issues, options, and ambiguities, and operational and implementation challenges. Flow charts of both current regulatory process and the Federally-Facilitated Marketplace alternative procedures are also available.

Consumer Notices

As Marketplaces establish their renewals process, they’ll need to consider potential approaches for messaging around complex topics, such as distinguishing between subsidy eligibility, QHP enrollment eligibility and coverage renewal, and the interaction between subsidy level and plan changes. This presentation provides an overview of the current regulations regarding consumer notices, as well as the federal alternative procedures. It also calls out the key messages that Marketplaces will need to convey to consumers.