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By Sara Hansard
Jan. 28 --Individuals who need to report a “life change” to the Department of Health and Human Services that affects their coverage or financial assistance under the Affordable Care Act will need to submit a whole new application, according to a plan posted on the Centers for Medicare & Medicaid Services technical assistance website.
The CMS posted a slide presentation for a Jan. 23 webinar, Change in Circumstances (CiC) Interim Functionality Update, for health insurers that sell qualified health plans (QHPs) on HealthCare.gov. Another webinar on the topic is scheduled for Jan. 30 from 1:00-2:30 p.m., it said.
The presentation outlines the process for people to make changes when they have life events for which they would have to change health plans or for which their eligibility for financial assistance under the ACA changes. The scheduled target to “promote to production” is Feb. 2, it said. That apparently means the HHS hopes to add the function to HealthCare.gov by Feb. 2, Timothy Jost, a professor with Washington and Lee University School of Law in Lexington, Va., told Bloomberg BNA in an e-mail Jan. 28.
Consumers will submit a new application to replace the original application so that eligibility can be redetermined for everyone on the new application, the presentation said. The federally facilitated marketplace will determine eligibility for a special enrollment period and permit eligible consumers to select a new plan, it said. Life events resulting in a special enrollment period eligibility are:
• adding a member, such as a birth or by marriage;
• losing access to other coverage, such as employer coverage;
• being released from incarceration; and
• changing citizenship or immigration status.
If a new plan is selected, consumers will be terminated from their original plan and enrolled in the new plan with no gap in coverage, it said. Consumers who don't qualify for a special enrollment period won't be permitted to change plans, but will re-select the original plan with updated information, it said.
The presentation also listed life events that don't result in special enrollment period eligibility: removing a member as a result of death or divorce; gaining access to other coverage, such as employer coverage; becoming pregnant; a change in tax filing status; a change in status as American Indians, Alaska Natives or tribal status; changes in disability status; corrections to date or birth or Social Security number; or some changes in income.
Brian Haile, senior vice president for tax policy with Jackson Hewitt Tax Service Inc., told Bloomberg BNA in an e-mail Jan. 27 that he was “a little surprised” that consumers must submit a new application to replace their original application. Haile has written about making the application process easier for consumers who are applying for coverage under the ACA.
“Up until now the exchanges have not been able to process changes of circumstances, which has been problematic because people's circumstances are constantly changing,” Jost said. “What this means now is that people whose circumstances change, who get married, have a baby or lose a job can go to the federal exchange and get that change taken care of.”
“We are committed to ensuring that consumers have continuity of coverage if they experience one of these life circumstances,” HHS spokeswoman Alicia Hartinger told Bloomberg BNA in an e-mail Jan. 28. “We are currently working with insurers to find ways to make changing coverage easier while we develop an automated way for consumers to update their coverage directly through the Marketplace. Issuers are also continuing their 'continuity of care policy' that allows families to add a new child onto the parents' policy for 30 days.”
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