2015 Re-Enrollment Rule
A recent update from the National Association of Health Underwriters regarding re-enrollment for the 2015 plan year for policyholders ON the insurance exchange:
This month, the Obama Administration finalized the 2015 Re-Enrollment Rule. Key points to keep in mind are:
• Consumers who do not denote otherwise will be re-enrolled in their current exchange plan on December 15, 2014, rather than right away. NAHU (The National Association of Health Underwriters) asked for a time-delay in re-enrollment in order to give consumers ample opportunity to review their plan options, which was granted.
• Those who are re-enrolled will be able to keep their 2014 subsidy as long as their income has not changed dramatically AND if they checked the box on their original application that allowed the IRS to view their tax returns (a reported 90% of consumers checked the box).
• If a consumer is enrolled in a plan that has been cancelled on the exchange, but offered outside of the exchange, they’ll be automatically enrolled in the plan off the exchange.
• If the plan has been cancelled altogether, the consumer will be enrolled in a plan of the same metal tier. If a similar tiered plan is not available, they will be automatically enrolled in a different plan of the same carrier and metal tier. If the carrier does not offer a different plan of the metal tier the consumer was previously enrolled in, the consumer will be enrolled in a plan one metal tier higher or one metal tier lower that they were previously enrolled in. If that still is not an option, then the consumer will be enrolled in “any other plan offered under the product in which the enrollee’s current QHP is offered in which the enrollee is eligible to enroll.
• If plan premiums go up, which they likely will, the consumers who are automatically re-enrolled will be on the hook for the price of the premium increase.
• The issue of consumers getting larger subsidies than they deserve still remains to be an issue and an industry-wide concern, despite the finalization of this rule. More on this to come.
We remain hopeful, but still have some concerns about how this re-enrollment process will work in practice, given some of the challenges associated with the exchanges this past year.