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The HEALTH INSURANCE MARKETPLACE: Special Enrollment Periods
ACA Name Enroll VA Title Work Address T: Work Number
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enrollment period When eligible individuals can enroll in a Qualified Health Plan (QHP) Marketplace will determine eligibility to enroll in a plan, determine eligibility for financial assistance and assess eligibility for Medicaid A person can only enroll in a QHP during Open Enrollment or during a Special Enrollment Period Applies to QHPs on the Marketplace and those off the Marketplace Medicaid has year round enrollment
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Open Enrollment Periods
Annual period when qualifying individuals can apply and enroll in a health plan Qualifying individual is someone who: Lives in the service area Is not currently incarcerated U.S. citizen, national, or will be lawfully present for the entire time coverage is sought Open enrollment for 2017 coverage: November1, 2016 – January 31, 2017 Open enrollment for 2018 coverage: November 1, January 31, 2018* Open enrollment for 2019 coverage: November 1, 2018 – Dec.15, 2018 * A proposed rule would change these dates to November 1, 2017 – Dec. 15, 2017
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Special Enrollment Periods
Enable individuals who experience certain qualifying life events to enroll in or change plans outside of Open Enrollment Can occur at any point during the year Usually gives someone 60 days to take action Usually applies to the entire family, even if only one person experiences the change Some are available to anyone and some are only available to those who are already enrolled in a Marketplace plan
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Qualifying life events For anybody
Loss of Minimum Essential Coverage because: A family member’s death Turned 26 and could no longer be on parent’s plan Lost dependent status Left or terminated from a job Lost eligibility for CHIP or Medicaid benefits Expiration of COBRA coverage Got a divorce Employer no longer offers coverage Employer coverage is no longer affordable or adequate Non-marketplace plan expired Lost eligibility for a student plan Does not include voluntary terminations or cancelation for non-payment of premiums
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Qualifying life events For anybody, cont’d
Permanent Move Resulting in access to new qualified health plans A short-term move for medical treatment or vacation is not considered a permanent move A child or dependent moves back to parent’s home A person moves to a different area for seasonal employment, but maintains another home elsewhere (such as seasonal formwork) Moving to the U.S. from abroad or a U.S. territory Must have had coverage for at least 1 day in the previous 60 days unless moving from abroad
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Qualifying life events For anybody, cont’d
Marriage Birth or adoption, if child is Marketplace eligible Gained eligible immigration status Left incarceration Income was below 100% FPL during Open Enrollment and is now above 100% FPL Survivor of domestic violence or spousal abandonment and is enrolled in a QHP, but wants to enroll in a plan separate from abuser or spouse Native American & Alaska Native (1x per month) Applied for Medicaid during Open Enrollment but was denied after Open Enrollment ended
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Example: income increase above 100% fpl
Jane (a household of one) was unemployed during Open Enrollment so her income estimate was $0. In June, Jane finds a job that will pay her approximately $36,000/yr. Can Jane attest that she will be make more than 100% FPL ($11,880 for a household of 1) between June and December 2017? January June December Yes! She will receive around $18,000 for the 2016 calendar year.
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Qualifying life events For anybody, cont’d
Complex Issues I was negatively impacted by an error, misrepresentation, misconduct or inaction by the Marketplace or other entity providing enrollment assistance (ex. Navigator, CAC, insurance company) Plan or benefit display error Exceptional Circumstances prevented enrollment Serious medical condition Natural disaster Winning a Marketplace Appeal
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Qualifying Life Events for Enrollees
Change in income Enrollee is newly eligible or ineligible for Premium Tax Credits Enrollee is newly eligible or ineligible for cost- sharing reductions Enrollee demonstrates plan violated contract
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Not qualifying life events
Voluntarily dropping other coverage Loss of eligibility for coverage when the person was not enrolled in it (i.e., loses job, but was not in the employer’s health plan) Being determined newly eligible for PTC if not already enrolled in a Marketplace QHP (unless coming out of the Medicaid coverage gap) Being terminated from other coverage for not paying premiums or for fraud Divorce or death of a family member if person does not also lose coverage as a result Becoming pregnant Moving within the U.S. if the person did not have coverage in at least one day in the past 60 days
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How to apply Standard Application can be used to apply for and be granted most Special Enrollment Periods Those already enrolled in marketplace coverage must update their original application Those not enrolled in Marketplace coverage can go to the Marketplace and start a new application Marketplace Call Center & CMS Casework must be used to access SEPs for: Income increasing over 100% FPL Complex Issues Exceptional Circumstances Survivor of domestic violence or spousal abandonment
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How to Apply: Multiple “doors”
Online Marketplace Marketplace Call Center Local assistance Enroll Virginia – Medicaid applications can be done year round online, through the Cover VA call center or at your local DSS www. commonhelp.virginia.gov
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Information Needed to Apply
Identity of applicants Names and contact info Social Security Numbers Immigration Status and Documents Household Size Using tax code principles to determine household size Tax dependents are in the tax filers household Estimated 2017 income Modified Adjustable Gross Income (MAGI) Adjusted Gross Income + non-taxable Social Security benefits + tax- exempt interest + tax-exempt foreign income Availability of employer-based coverage and it’s cost Proof of qualifying life event Databases will verify most information, paper documents used for discrepancies
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When to apply All SEPs are available 60 days after the qualifying life event You must apply and enroll before the 60 days ends Loss of Coverage SEP can be accessed 60 days before or 60 days after the loss of coverage, this can help avoid a gap in coverage
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Eligibility Once an application is completed, you will get an eligibility determination notice that will inform you of: Your eligibility for a special enrollment period The dates of your special enrollment period Your eligibility for financial assistance Is any documents must be submitted You can then enroll in or switch plans
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Eligibility For Financial Assistance
Premium tax credits reduce the amount you pay for your premium. Must have income between 100% and 400% FPL. Cost sharing reductions lower your deductibles, co-pays and out of pocket costs. Must have income between 100% and 250% FPL.
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2016 Federal Poverty Guidelines
Note: Medicaid applications will be assessed using 2017 thresholds
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Effective dates Normal effective dates apply with few exceptions
If you enroll by the 15th of a month, the coverage will being the 1st of the next month If you enroll after the 15th of a month, the coverage will being the 1st of the second following month Exceptions Loss of coverage if SEP accessed before the loss occurs 1st day of month following plan selection Marriage and death Birth/adoption/placement in foster care - enrollee can choose: Date of birth/adoption/placement, or 1st day of the month after birth/adoption/placement, or Regular coverage effective dates
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Post-enrollment verification
Some SEPS require proof of eligibility to be submitted. Enrollees will be able to enroll at time of application, but must submit required documents within 30 days or risk losing coverage for: Loss of minimum essential coverage Proof of previous coverage and date of loss Permanent move Old address New address Proof of previous coverage Birth Adoption, placement for adoption, placement or foster care or child support or other court order Marriage
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Pre-enrollment verification Pilot Program
Beginning in June 2017, the Marketplace will require 50% of SEP applicants to submit proof of SEP eligibility before they will be allowed to enroll in coverage. All SEP types will be subject to verification. Effective date will usually be determined by the date of plan selection. The enrollment will be pending until the individual submits documents. There will be situations where consumers can request a prospective coverage effective date if verification is delayed for 2 months or longer. The consumer will have 30 days to submit requested documents, if documents are not received the consumer will not be enrolled in the plan. The consumer must pay your first premium for the coverage to begin once their eligibility has been verified.
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Exemptions & Penalty If you do not access an SEP and go without coverage you may have to pay a penalty Everyone is required to have minimum essential coverage (MEC), pay a penalty, or get an exemption Taxpayer is responsible for dependents Coverage requirement, penalties, and most exemptions apply on a monthly basis One day rule: A person has coverage entire month if covered for at least one day of that month A person is eligible for an exemption entire month if they are exempt for at least one day of that month. 2017 penalty is $695 per adult + $ per child up to $2085 or 2.5% family income above the tax filing threshold
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Exemptions Granted by Marketplace Granted at Tax Filing
Hardship, including: Experienced homelessness, an eviction or foreclosure, or received a utility shut off notice. Bankruptcy Victim of domestic violence Determined ineligible for Medicaid in a state that did not expand Medicaid coverage Plan cancellation Member of certain religious sects Other Insurance in unaffordable based on projected income Granted at Tax Filing Income below filing threshold Insurance is unaffordable Certain noncitizens Short coverage gap (<3 months) Gap before effective date of Marketplace coverage purchased during open enrollment Having income below 138% FPL in a state that did not expand Medicaid Health care sharing ministry Indian tribe membership Incarceration US citizen living abroad for more than 330 day in the year An exemption for a state’s failure to expand Medicaid can be received by applying for coverage directly at healthcare.gov if you are below 100% FPL
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QUESTIONS? Phone Number email@enroll-virginia.com
@EnrollVirginia
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Thank you! ENROLL Virginia! is a nonprofit, nonpartisan entity that assists individuals and small businesses to obtain health insurance including commercial health coverage through the federally facilitated health insurance marketplace, to qualify for applicable tax subsidies, and to comply with the U.S. Patient Protection and Affordable Care Act and avoid penalties for failure to do so. The program is paid for by a federal grant (Funding Opportunity Number CA- NAV from the U.S. Department of Health and Human Services, Centers for Medicare & Medicaid Services) and administered by the Virginia Poverty Law Center. The contents provided here are solely the responsibility of the authors and do not necessarily represent the official views of HHS or any of its agencies. “This project is supported by the U.S. Department of Health and Human Services, FOA CA-NAV from CMS. The contents provided are solely the responsibility of the authors and do not necessarily represent the official views of HHS or any of its agencies.”
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