Column 77 Special Enrollment

Are you special?  I bet you would like to think so. If you would like your employees to think so too, you might be interested to know that the ACA requires that carriers accept small business customers even if they don't meet minimum participation or contribution requirements during an annual special enrollment period beginning on November 15th and ending Dec. 30th for most carriers.  Could be a great Christmas gift for your employees!

If you have wanted to provide group insurance, but were worried you could not meet the insurance company minimums for participation, now is the time to apply.  Your group can be effective 1/1/2015 if you get your application in this month. For business owners who are not happy with the small provider networks and Rx benefits in the individual market, here is your chance to regain the benefits of group insurance and not worry that you don't have enough people participating.

With the holidays approaching you want to get on this one right away!

Another fun thing to keep in mind for small groups is the new waiting period limitations.  Depending on the renewal date of your group, you need to be aware of your options.  In accordance with SB 1034, groups are responsible for ensuring that any group imposed waiting period is consistent with Section 2708 of the federal Public Health Service Act (42 U.S.C. Sec. 300gg-7). How is that for a mouthful?

Following are the waiting period options for renewals effective January 1, 2015:

·    First of the month following date of hire.

·    First of the month following one month from date of hire.

·    First of the month following two months from the date of hire, not to exceed 90 days*

Be sure to consult with your broker or insurance carrier to verify the rules for your group, based on your renewal date and the carrier.

Deadlines, Deadlines, Deadlines....

We are happy that the Medicare Part D open enrollment period has ended. As of Sunday December 7th, if you have not changed your stand-alone Medicare Rx plan, you may not do so until next fall.

Individuals under age 65 are facing the first deadline tomorrow.  If one wants insurance to be effective 1/1/2015, applications must be processed by midnight on Monday 12/15/2014.  It is important to remember that if you are not eligible for a subsidy, there is no reason to add the additional layer of administration by going through Covered CA.  However, if you are eligible, you MUST apply through Covered CA to claim the subsidy.

The subsidy can come in the form of premium and/or benefits.  If a family of four has income under $95,400, they may be eligible for cash help with paying premiums.  If the income is between about  $32,914 and $59,000 they could be eligible for enhanced benefits as well. 

The term "enhanced silver" is causing a lot of confusion to those who have enrolled in a standard silver plan on Covered CA.  The system generates a letter that says something to the effect of "you are not eligible for the following benefits: Enhanced Silver".  This has caused more than one person who enrolled in a Silver plan to panic and think they are not eligible for the plan in which they enrolled.  Do not be alarmed.  That merely states that you do not get the Enhanced Benefits that are provided to people with incomes between 138% and 213% of the Federal Poverty Level.


There is also some confusion about grace periods.  That is if the premium is not paid by the due date, when can the carrier cancel your coverage? 

Under current law in California, SB2X sets the grace periods. For ACA "on Exchange "members who get a government premium subsidy, the grace period is 3 months, for ACA members who do not get a government premium subsidy, the grace period is 31 days. Clearly the government has a "favorite child". 

 I have written multiple times about the fact that individual policies are "in state only plans".  This means that coverage out of state is only provided in the event of emergencies that present a threat to life or limb, i.e. emergency or urgent care.  However when you look at the options on the Exchange, it shows the Anthem plans as MSP (Multi State Plan).  To quote the authorities: "These plans do not have coverage in "Multiple States" like the designation might suggest.  "Multi-State" is simply a designation and does not mean the plans provide coverage in other states."

I expect like me, you can't help but smile at that one!  Who said people who make these rules don't have a sense of humor?