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Monday, March 10, 2014

The Clock Is Ticking: Will Health Care Consumers Be Able to Finish Enrolling Before March 31?

Last Wednesday, the Department of Health and Human Services (HHS) made two announcements about open enrollment periods:

1. Open enrollment for 2015 will take place November 15, 2014 through February 15, 2015—a month longer than HHS had initially contemplated. This is welcome news!

As we saw this year, it takes time:

  • To share exactly when consumers can enroll in health plans;
  • For people to gather information, review their options, and select a plan; and
  • For government agencies to iron out any systems problems to ensure the enrollment process functions smoothly. Furthermore, navigators and assisters need time, outside of holiday periods, to help people complete the process.

2. There will be no change in the enrollment period for this year—enrollment will end on March 31, as scheduled. We all have an important role to play in reminding consumers to get busy and enroll now.

HHS and state-based marketplaces should take immediate steps to ensure that consumers who try to enroll on time, but get stuck, can complete the process.

First, marketplaces should assure that people who have started applications are given special enrollment periods to finish the enrollment process even after open enrollment ends. With so many technological problems, process changes, and professional staff (like call center staff, brokers, and enrollment assisters) who were still learning the ropes even after enrollment began, many people who have begun the process will not have completed it by March 31. For example, some people are submitting additional documents to prove their identities; some consumers’ online applications went missing when they tried to correct information; the marketplace erroneously referred some consumers to Medicaid, when in fact they qualified for marketplace coverage. And without knowing the reason someone got stuck in the process, marketplaces should give consumers the benefit of the doubt by allowing them to complete the enrollment process, so long as they began it before March 31. Rules say that marketplaces “may” allow for special enrollment due to marketplace errors. We urge marketplaces to take this action.

While that is an important step to ensuring we get as many people covered, the next step is to inform health care consumers about their opportunity to continue the application process. This will require outreach efforts to contact all consumers (for whom that state’s marketplace has records) asking if consumers want to complete their enrollment applications and whether they need help. Then, marketplaces, navigators and assisters, and call centers, must provide that help.

In some cases, consumers who started an application but were unable to complete it because of marketplace error may want to get coverage retroactively to the date that they would have been enrolled had the systems functioned correctly. For example, if someone had a need for medical care during the period they would have been covered if their enrollment had been successful, they should not be required to pay the full cost of that care out-of-pocket because of a bureaucratic error. Guidance published February 27 allowed, but did not require, marketplaces to provide retroactive coverage and retroactive premium credits to correct errors. To correct any errors, all marketplaces should offer retroactive coverage, though retroactive coverage may not be the right choice for every consumer’s circumstance: Some consumers will not want to pay retroactive premiums for a period before their enrollment was processed, and they should be able to begin coverage later.

With the first open enrollment period ending soon, marketplaces should do the right thing by consumers—gaining good will, employing good business practices, and getting more people covered are important milestones along the way as we establish this new health care system.