CMS Guidance on How Grace Periods Will Interact with the FFM Renewal and Reenrollment Process

A grace period is a short period of time a consumer may be given to pay his or her health insurance plan premium after the due date has passed. Consumers receiving advance payments of the premium tax credit (APTC) who have paid at least their first month’s premium in full are entitled to a grace period of three consecutive months that begins the month that they first miss a premium payment. CMS recently released guidance, REVISED Bulletin 10: Guidance on Grace Periods in the FFM that describes how grace periods interact with the renewal and re-enrollment process for the 2015 benefit year. Specifically, the guidance applies to consumers currently enrolled in a Marketplace plan who are in a grace period spanning two benefit years (e.g., 2014-15), and whose grace period takes place during Open Enrollment. An expired grace period that results in terminated 2014 coverage affects consumers’ 2015 enrollment differently based on whether the 2015 plan is a renewal or a re-enrollment into a different product. Note that the term “renewal” applies if a consumer’s 2015 enrollment is in a plan within the same 2014 product.  Plans that are within the same product have Plan IDs beginning with the same first ten characters. The term “re-enrollment into a different product” applies when a consumer selects a plan for 2015 that starts with a different ten character sequence than his or her 2014 plan. (For more information on how consumers can find their plan IDs, please see, “How do I find my plan ID?” on HealthCare.gov.)

  1. If consumers actively enroll or are automatically re-enrolled into a plan within the same product as their 2014 plan during a grace period that begins in 2014 and extends through 2015, they will be enrolled for 2015 coverage. However, the issuer may attribute new payments received to the outstanding debt from the 2014 grace period.
  2. If consumers actively enroll or are automatically re-enrolled in a plan within a different product during a grace period that begins in 2014 and extends through 2015, the issuer must accept the enrollment, and cannot apply any enrollee payments for the new coverage to outstanding debt from any previous coverage. However, like other enrollees, these consumers will be required to pay the first month’s premium of the new plan in order to have coverage effectuated.
  3.  If consumers actively re-enroll or are auto re-enrolled into a plan within the same product and if consumers’ grace periods end on December 31, 2014 and they have not paid their outstanding premiums, the issuer can accept or reject their auto renewal or active renewals. In these cases, the issuer must apply the same policy to all enrollees and cannot discriminate based on health status or other prohibited bases. However, if these consumers choose a different product and/or a different issuer, the issuer must accept the enrollment and cannot apply any enrollee payments for the new coverage to outstanding debt from any previous coverage.
  4.  Active renewals or auto renewals (into the same product) do not necessarily require that the consumer pay a full month’s premium to maintain coverage since renewed coverage is considered previously effectuated. Rather, any nonpayment for a renewal is subject to the applicable grace period and triggers termination for nonpayment only if the grace period has expired. For example, if a consumer’s grace period began on December 1, 2014 and he or she actively renews coverage or is auto re-enrolled into a plan of the same product, coverage will continue even without a premium payment for January until the grace period ends at the end of February 2015, when coverage would end retroactive to the last day of December 2014 if the consumer has not paid his or her premiums for December, January, and February.

Termination for Non-Payment of Premiums If consumers’ grace periods span the 2014 and 2015 coverage years, and they are auto re-enrolled or actively renew their coverage but do not pay their premiums, the original coverage and the renewed coverage will end retroactive to the last day of the first month of the grace period. If the Open Enrollment Period is still ongoing, consumers may come back and actively enroll in a plan offered by the same issuer (even of the same product) under guaranteed availability rules, paying the first month’s premium to effectuate coverage without the issuer applying the payment to previous debt.  If coverage is terminated after the end of Open Enrollment, however, consumers will not be able to enroll in a new Marketplace plan unless they qualify for a special enrollment period. Please remind consumers who re-enroll in coverage during a grace period that they must pay their premiums for their coverage to continue. As a reminder, consumers whose 2014 coverage ended because they did not pay their premiums can select 2015 Marketplace coverage. Additionally, consumers in this situation can select plans from the same health insurance company that terminated their 2014 coverage if they choose, and the health insurance company cannot use their premium payments to cover outstanding debt.

Summary of Auto Re-Enrollment, Active Re-Enrollment, and Choosing a Different Marketplace Product for Consumers Whose Grace Periods Span Coverage Years (2014-2015)

Type of Enroll during grace

 

 

 

 

 

 

 

 

To view the assister tip sheet that includes information about grace period eligibility, click here: http://marketplace.cms.gov/technical-assistance-resources/helping-consumers-grace-period.pdf.

Open Enrollment Update – Week 3

Open Enrollment Week 3: November 29 – December 5, 2014

More than 1.3 million consumers have selected plans since the beginning of Open Enrollment.  As we approached the December 15 deadline for coverage that starts January 1, 2015, interest increased – last week’s plan selections were 33 percent higher than the first week, and double the number of plan selections during the week of Thanksgiving.

Each month, HHS will produce a report that provides a detailed look at plan selection across the Federally Facilitated Marketplace (FFM) and State-Based Marketplaces. In addition, CMS is releasing weekly snapshots of preliminary data. These snapshots do not include the consumers who visited, called, shopped or selected a plan through a State-Based Marketplace.

The weekly Open Enrollment snapshots for the FFM provide point-in-time estimates for weekly data. These are preliminary numbers and could fluctuate based on consumers changing or canceling plans or having a change in status such as new job or marriage. The snapshots also include totals from the beginning of Open Enrollment. Note that data revisions may mean that the weekly totals do not sum to the cumulative numbers.

Definitions and details on the data are included in the glossary.

 

 

 

 

 

 

 

 

Consumers can shop and sign up for affordable health coverage that fits their health and financial needs any time between now and February 15, 2015. For coverage to start on January 1, 2015, consumers should have enrolled in a plan by December 15, 2014. Most consumers who were enrolled in a QHP last year and who did not take action before the deadline will be automatically enrolled by their insurance company into their current plan or a plan with similar benefits.

Glossary

Plan Selections:  The weekly and cumulative metrics provide preliminary totals of those who have submitted an application and selected the plan that best fits their needs.  As noted previously, these numbers fluctuate based on consumers changing or canceling plans or having a change in status such as new job or marriage; changes for the entire open enrollment period are reflected in the most recent weekly and cumulative metrics.

To have their coverage effectuated, consumers need to pay their first month’s health plan premium. This release does not include effectuated enrollment.

All references to the Marketplace in this report refer to the 35 states that used the HealthCare.gov platform in both 2014 and 2015, and Oregon and Nevada, which are new to the FFM platform in 2015. Those states include: Alabama, Alaska, Arizona, Arkansas, Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Louisiana, Maine, Michigan, Mississippi, Missouri, Montana, Nebraska, New Hampshire, New Jersey, Nevada, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, West Virginia, Wisconsin, and Wyoming.

New Consumers:  New consumers are those consumers who are selecting a plan for the first time or whose plan selection in 2014 was terminated, because, for example, they failed to pay their premium or gained coverage through employer-sponsored insurance. In addition, because Oregon and Nevada consumers now use the FFM platform, all plans chosen by consumers in those states are considered new enrollments.

Consumers Renewing Coverage:  Consumers with 2014 effectuated enrollment who have actively submitted a 2015 application and selected a plan or, after December 15, have been auto-renewed.

Applications Submitted:  A consumer who has completed an application and submitted it. If determined eligible for Marketplace coverage, the consumer still needs to pick a health plan that best fits their financial and health needs and pay their premium to get covered. Because families can submit a single application, this figure tallies each person covered by an application. The weekly and cumulative metrics total the number of people who have submitted an application.

Call Center Volume:  The total number of calls received by the FFM call center over the course of a week or from the start of Open Enrollment.

Calls with Spanish Speaking Representative:  The total number of calls received by the call center where consumers chose to speak with a Spanish-speaking representative. These calls are not included within the Call Center Volume metric.

Average Call Center Wait Time: The average amount of time a consumer waited before reaching a customer service representative. The cumulative total averages wait time over the course of the extended time period.

HealthCare.gov or CuidadodeSalud.gov Users: The user metric totals how many unique users viewed or interacted with either HealthCare.gov or CuidadodeSalud.gov over the course of a specific date range. For cumulative totals, a separate report is run for the entire Open Enrollment period to minimize users being counted more than once during that longer range of time and to provide a more accurate estimate of unique users. Depending on an individual’s browser settings and browsing habits, a visitor may be counted as a unique user more than once. Note: in reporting from the last open enrollment period “users” was reported as “unique visitors.

Window Shopping HealthCare.gov Users or CuidadoDeSalud.gov Users: The user metric totals how many unique users interacted with the window-shopping tool over the course of a specific date range. For cumulative totals, a separate report is run for the entire Open Enrollment period to minimize users being counted more than once during that longer range of time and to provide a more accurate estimate of unique users. Depending on an individual’s browser settings and browsing habits, a visitor may be counted as a unique user more than once. Users who window-shopped are also included in the total HealthCare.gov or CuidadodeSalud.gov user total. Note: in reporting from the last open enrollment period “users” was reported as “unique visitors.”

NACHC Collecting Health Center Stories to Celebrate the 50th Anniversary of the Health Centers Program

Starting early next year, Community Health Centers will celebrate 50 years as a vital movement in expanding access to care to millions of people nationwide. NACHC will host anchor events and a communications campaign with the goal of celebrating the people and achievements of the Health Center Movement and bringing attention to the value of Health Centers to the American healthcare system, particularly as the threat of the funding cliff draws nearer. For its communications efforts, NACHC is identifying Health Center stories that showcase the value of Health Centers and the immediate threats they face with cliff. Please send your stories and examples along with a brief description of a story as well as your and your center’s contact information, location, and state to NACHC’s communications team at asimmons@nachc.org and mballantyne@nachc.org.

Families USA Open Enrollment Hub

Families USA Open Enrollment Hub

Families USA has launched an online resource for Open Enrollment that showcases their outreach and enrollment resources for assisters. On this page you’ll find featured My Coverage videos, announcements for teleconferences with Marketplace experts, resources for enrollment assisters, consumer-friendly infographics, and more.

Targeted Outreach Strategy for Immigrant Applicants Under 100% FPL Who are Eligible for Tax Credits and not Eligible for Medicaid

Most applicants who have an annual income under 100% of the FPL are not eligible for advance premium tax credits (APTC) or cost sharing reductions (CSR); with one exception. As long as all other eligibility criteria are met, a lawfully present individual whose income is under 100% of the FPL and who is not eligible for Medicaid based on immigration status is eligible for APTC and CSRs.

Over the last year, CMS has made improvements to Healthcare.gov to make it easier for certain lawfully present immigrants to get the tax credits they are eligible for through the Marketplace. While the vast majority of eligible immigrants are being appropriately determined eligible for APTC and CSRs, some applicants have had trouble receiving an accurate eligibility determination. This generally occurs when the Department of Homeland Security’s SAVE system is unable to verify their immigration status, or when the consumer is unable to obtain an immigration-specific denial from Medicaid. CMS has identified a group of consumers who, based on their data, may be eligible for APTC and CSRs. CMS is conducting targeted outreach to determine if these individuals are indeed eligible for APTC and CSRs and if so, to facilitate enrollment.

Using 2014 application data, CMS has identified immigrant applicants who (1) have a resolved or unresolved QHP immigration data matching issue (2) have requested financial assistance, and (3) have an annual income under 100% of the FPL. Most of these applicants live in non-expansion states. Applicants who meet these three criteria should receive a notice from the Marketplace asking them for immigration documents.

The notice instructs applicants with an immigration data matching issue to send documentation proving immigration status. Once documentation is submitted, the Marketplace will review this documentation to verify the applicant has a Medicaid-ineligible and a QHP-eligible immigration status. Applicants who send documentation that is insufficient to prove immigration status will receive another letter requesting more specific documentation. Please note that the Marketplace will not send this notice to consumers who have previously submitted sufficient information to resolve their immigration data matching issue.

If an applicant is found to have QHP-eligible immigration status and Medicaid-ineligible status, based on the submitted documentation, the applicant will receive another notice. This notice will notify applicants of their data matching resolution and encourage the applicants to return to the Marketplace application to answer specific questions to determine if they are eligible for APTC and CSRs. Consumers can login to their Healthcare.gov account and follow detailed, step-by-step instructions in the notice or contact the Marketplace Call Center and speak to a trained representative. Please note that the Marketplace will send this notice only to applicants who provide sufficient documentation to show that they are potentially immigration-eligible for APTC or CSRs despite being under 100% FPL.

This outreach strategy will be used on an ongoing basis to help consumers get a correct eligibility determination when they apply for 2015 coverage.

Preparing for Tax Season: What HRSA Grantees Need to Know About Premium Tax Credits and the Individual Shared Responsibility Payment webinar on Dec. 16 at 12:30pm CT (11:30am MT)

Next week, the Health Resources and Services Administration (HRSA) and the Internal Revenue Service (IRS) will host a webinar on the tax implications of the Affordable Care Act.  The IRS will provide information on premium tax credits, the reconciliation process for advanced premium tax credits (APTCs), Individual Shared Responsibility Payments (also known as “the fee for not having coverage”), and navigating new and updated IRS Tax forms such as the 1040 and Form 8962. IRS presenters will be available at the end of the webcast to answer questions. The webinar will also include information for Ryan White HIV/AIDS Program grantees that provide premium assistance to clients who receive APTCs from the Health Insurance Marketplace.

Guest Blog – “500 by the 15th” Campaign to Encourage Nebraskans to Get Health Coverage

By Guest Blogger Jeff Sheldon, Communications Director, Nebraska Appleseed

Statewide health care organizations available to provide free assistance

Today, community and health care organizations across Nebraska announced the kickoff of a new effort to ensure Nebraskans get vital health insurance in December.

The “500 By The 15th” campaign seeks to help Nebraskans who need health coverage, but may feel they cannot afford insurance, to explore their options using free, in-person assistance that is available statewide.

Enroll Nebraska, a statewide network of health care providers, community organizations, in-person assisters, and advocacy groups, announced the goal of helping 500 Nebraskans enroll in coverage or renew coverage through the Health Insurance Marketplace by December 15.

“Nebraska is a better, stronger state when our people are healthy, and part of maintaining health is being able to get needed medical care,” said Keshia Bradford, Director of Outreach and Enrollment for the Health Center Association of Nebraska. “The Health Insurance Marketplace has many different options for coverage for Nebraskans, and with tax credits, plans are affordable.”

To help reach the goal of helping 500 Nebraskans enroll or renew in coverage by December 15, organizations are planning extended hours, special events to promote enrollment assistance, or increased outreach efforts to spread the word about the free help that is available for Nebraskans to look at different insurance plans.

Nebraskans can get assistance to understand health coverage options at local Community Action Partnerships, local public health departments, or members of the Health Center Association of Nebraska. See this map to find free local help. Or people can get help over the phone by calling, toll-free 1-800-318-2596.

“During the last enrollment period, more than 40,000 Nebraskans signed up for the health coverage through the Health Insurance Marketplace. It was a huge success in our state,” said Eric Savaiano, Statewide Coordinator for Enroll Nebraska. “We want to continue that success this year by helping even more Nebraskans get the health coverage that leads to healthy families, productive employees, and strong communities.”

 

 

 

 

 

Basic Disaster Life Support Webinar Series – Jan. 8 – Feb. 26, 2015 on Thursdays 11am-12pm CT (10am-11am MT)

The Center for Preparedness Education offers a Basic Disaster Life Support Webinar Series:

OBJECTIVES:

The BDLS® course is a review of all-hazards topics including natural and accidental man made events; traumatic and explosive events; nuclear and radiological events; biological events; and chemical events (CBRNE) as well as mass casualty triage.  Additionally, critical areas such as the health care professional’s role in the public health and incident management systems, community mental health, and special needs of underserved and vulnerable populations are addressed in the course curriculum.

WHEN: January 8 – February 26, 2015 

Webinar Topic Thursdays 

11:00-12:00pm CT

Introduction & Disaster Basics January 8
Biologic Disasters January 15
Workforce Readiness & Deployment January 22
Chemical Disasters January 29
Mass Casualty & Fatality Management February 5
Explosive & Radiologic Disasters February 12
Public Health Emergency Response February 19
Natural Disasters February 26

*Must attend ALL Sessions*

AUDIENCE

EMS, Fire, Nurses, Physicians, Physician Extenders, Respiratory Therapists, Allied Health Professionals, Public Health, Emergency Management, and others interested in disaster response.

REGISTRATION

Register Here

by Jan 1, 2015 as class size is limited

Cost is $200 includes Textbook

 

CONTACT

Leslie Scofield at lscofield@unmc.edu or 402-552-3116

 

 

 

 

 

NEW RESOURCES: Obtaining Consumer Authorization and Handling Consumers’ Personally Identifiable Information (PII) Guidance/ UPDATED Marketplace Assister Earned Media and Promotion Toolkit / SAMHSA Materials and Webinars on the ACA and Mental Health / SHOP Presentation Slides / Open Enrollment Webinar Presentation Slides

1. Obtaining Consumer Authorization and Handling Consumers’ Personally Identifiable Information (PII) Guidance

An updated version of the Marketplace Assister Earned Media and Promotion Toolkit from the CMS Office of Communication is available. This toolkit provides strategies and templates for use in outreach to media and your community in order to drive traffic to Marketplace assister services and community enrollment events.

2. UPDATED Marketplace Assister Earned Media and Promotion Toolkit

Several guidance documents for assisters related to handling consumer’s personally identifiable information (PII) are available, including draft model consumer authorization (or consent) forms.  The documents are listed below along with the original links to provide a complete list.

Please review this guidance carefully, as it will help you and your assister organization better understand how to interpret and apply the privacy and security requirements to your work. The guidance also includes “best practices” for how to keep consumer information private and secure when performing your duties.

Please note that the model consumer authorization forms are drafts and subject to change; nonetheless, you may adopt the draft model forms immediately to ensure that you have consumers’ express consent. If you want to modify the form, please refer to the consumer authorization tip sheet (located at the second link below) to understand what information must be included, at a minimum, on the modified form.

The following documents are available on the Marketplace.cms.gov website:

These materials, along with other Guidance & Regulations on Assister Programs, are also available on the Technical Assistance Resources website: https://marketplace.cms.gov/technical-assistance-resources/assister-programs/guidance-regulations-on-assister-programs.html

3. SAMHSA Materials and Webinars on the ACA and Mental Health

The Substance Abuse and Mental Health Services Administration (SAMHSA) has partnered with CMS to provide outreach and education for the Affordable Care Act during Open Enrollment.  SAMHSA will be hosting a series of webinars on the following topics: ACA 101, Health Insurance Marketplace, Health Insurance Literacy, Coverage 2 Care (C2C), and Champions for Coverage. The agency will also provide training for assisters on how to work with communities and individuals who have behavioral health illnesses.

Infographics on ACA and Mental Health:  SAMHSA has created five infographics on the Affordable Care Act and Mental Health.  A few of the infographics address access to behavioral health services through the ACA, ACA coverage for severe mental disorders, and what the ACA means for behavioral health.

4. SHOP Presentation slides

The November 12, 2014 assister webinar featured a presentation on the Federally-facilitated Small Business Health Options Program (FF-SHOP). SHOP Marketplaces can be run by the federal government or by the state in which the Marketplace operates.  This presentation focused on the SHOP Marketplace run by the federal government. It provides an overview of the FF-SHOP Marketplace; explains how assisters can help consumers explore, apply for, and enroll in coverage through the FF-SHOP Marketplace; and includes where to direct consumers if they want to work with a local agent or broker. The presentation also provides links to additional tools and resources enrollment assisters may find useful when working with consumers who are interested in the FF-SHOP Marketplace. To view the slides from this presentation, please see the link below; we also featured a longer summary of the presentation in last week’s (November 18, 2014) assister newsletter. Finally, if you’re unsure whether your state uses the FF-SHOP Marketplace (which this program addresses) or runs its own SHOP Marketplace, please visit HealthCare.gov for more information.

5. Open Enrollment Webinar Presentation Slides

On Wednesday, November 19, CMS presented a webinar on the Open Enrollment process for consumers new to the Marketplace. The webinar covered the launch of Open Enrollment, provided an overview of new HealthCare.gov features and provided information about when and how individuals and families can apply for and enroll in coverage during Open Enrollment. (Note that this webinar topic was the rescheduled topic from the October 29 webinar that experienced technical difficulties.)

Best Practices for Reporting Issues to CMS

Assisters are a valuable resource in reporting issues affecting consumers to CMS, including technical issues related to the Marketplace. When reporting issues to contacts within CMS, such as a Navigator Project Officer, the “CACQuestions” mailbox, or other CMS personnel, as a best practice, we recommend including the following information:

  • When reporting online application issues, please include screenshots, error codes, time/date, operating system, application ID, and user name.
  • When reporting online account issues, please include username and email addresses, whether the consumer is accessing a new or returning account.
  • When reporting issues with the plan information displayed on HealthCare.gov, please include plan ID, zip code, and identify which part of the plan selection flow seems to be affected (i.e. the premium estimator tool).
  • When reporting issues with the Call Center, please include the date and time of the call, the number the call was made from.

As a general rule of thumb, the more information you can provide, the better able we’ll be to fully investigate and address the issue.

CMS realizes that the information you share with them to troubleshoot issues may contain consumers’ personally identifiable information (PII), which is information that, whether alone or in combination with other information, can be used to identify an individual.  As a best practice, CMS recommends that organizations protect emails containing consumer PII, such as by using encryption methods. If you are a Navigator or CAC that is sending PII through email, please note that there is nothing in your privacy and security standards that requires you to use email encryption systems.  Rather, the privacy and security standards require Navigators and CACs to generally keep PII private and secure and share PII with others only to the extent necessary. Unless your organization is required to encrypt emails containing PII under other federal or state laws or regulations, your organization should look to its own policies and procedures to determine whether emails containing PII should be sent using email encryption methods.