They’d have 30 days to submit their proof of SEP eligibility, and as long as they did so, their policy would be effective as of the date determined by the date of their application/plan selection (so for example, a person could enroll on July 10 for an August 1 effective date, but the enrollment would then be pended.
If the applicant submits proof of SEP eligibility on August 5, the enrollment would be completed, with coverage effective August 1).
At Health Affairs, Tim Jost suggested some alternative solutions, including a requirement that insurance carriers pay broker commissions for SEP enrollments in order to incentivize brokers to help more people enroll, and a requirement that group health plans provide certificates of creditable coverage to people losing their group coverage (this used to be required, but isn’t any longer; reinstating a requirement that the certificates be issued would make it easier for people to easily prove that they had lost coverage and had thus become eligible for a SEP).
But for the time being, the eligibility pilot program and the enhanced verification are part of the SEP enrollment process in the federally-run exchange (Health Care.gov).
The next open enrollment period, for coverage effective January 1, 2019, will begin November 1, 2018, and will end December 15, 2018.
The ten states that extended open enrollment for 2018 coverage are not likely to do so for 2019 coverage, as the dates for 2019 enrollment have been set since late 2016, whereas the dates set by the federal government for enrollment in 2018 plans were not finalized until April 2017.
In addition, when exchanges grant special enrollment periods based on “exceptional circumstances” those special enrollment periods apply within the exchanges; off-exchange, it’s up to the carriers as to whether or not they want to implement similar special enrollment periods. In many cases, they’re the same things that count as a qualifying event for employer-based plans.
But some are specific to the individual market under Obamacare.
Some have implemented verification programs and some have not.Open enrollment for 2018 ended on December 15, 2017 in most states, although ten states have extended open enrollment beyond that date (and people in many states have special enrollment periods due either to hurricane-related events in 2017 or an insurer leaving the market at the end of 2017 — these special enrollment periods are addressed below). There, off-exchange carriers are required to offer year-round enrollment, but they can impose a waiting period of up to 90 days before benefits become effective.But in every other state, ACA-compliant plans, both on and off-exchange, are not available for purchase outside of open enrollment.Starting in June 2017, HHS was planning to implement a pilot program to further enhance SEP eligibility verification (this plan was created by HHS under the Obama Administration).50 percent of SEP enrollees were to be randomly selected for the pilot program, and their enrollments would be pended until their verification documents are submitted.Note that most qualifying events apply both inside and outside the exchanges. For policies sold outside the exchanges, there are a few qualifying events that HHS does not require carriers to accept as triggers for special enrollment periods (however, the carriers can accept them if they wish).These include gaining citizenship or a lawful presence in the US or being a Native American (within the exchanges, Native Americans can make plan changes as often as once per month, and enrollment runs year-round).As a result, the individual market now utilizes annual open enrollment windows and allows for special open enrollment triggered by qualifying events.So even if you didn’t select a plan by December 15, you could still have an opportunity to enroll in ACA-compliant coverage for 2018 if you experience a qualifying event.In September 2016, HHS answered several frequently asked questions regarding the verification process for qualifying events, and noted that SEP enrollments since June were down about 15 percent below where they had been during the same time period in 2015 (after staying roughly even with 2015 numbers in the months prior to implementation of the new eligibility verification process).But HHS stopped short of issuing an explanation for the decline: it could be that people were previously enrolling who didn’t actually have a qualifying event, but it could also be that the process for enrolling had become more cumbersome due to the added verification step, deterring healthy enrollees from signing up.