ACA Special Enrollment Period (SEP) Announcement by CMH during PHE Unwinding

The spread of COVID-19 in 2019 was declared a Public Health Emergency (PHE), and it was necessary to make amendments to the healthcare policies. The state Medicaid agencies made rapid decisions to make systematic changes, modify their programs, and amend their policies to ensure the healthcare system was ready to cope with the global pandemic. One of the changes made by Medicaid during that time was to issue a continuous enrollment period for people who were enrolled in a Medicaid program on March 18, 2020 or enrolled afterward. Another rule passed during those challenging times was to offer a continuous enrollment period for people enrolled in a Children’s Health Insurance Program (CHIP).

According to the recent Consolidated Appropriations Act, 2023, the continuous enrollment period issued by COVID-19 PHE will no longer be available, and this condition will terminate on March 31, 2023. This will result in the termination of Medicaid enrollment on April 1, 2023, for people who do not meet the eligibility criteria.

The Centers for Medicare and Medicaid Services (CMS) has further issued the guidance that once the continuous enrollment condition is expired, the states will have 12 months, known as the “unwinding period,” during which they can initiate renewal for individuals who were previously enrolled in Medicaid, CHIP, and in some cases the Basic Health Programs (BHP). This process is referred to as “unwinding.” Furthermore, the states will have 14 months to complete this process.

With all these changes in place, many beneficiaries who do not meet specific criteria will lose their Medicaid coverage on March 31, 2023, when the continuous enrollment condition ends, and the unwinding period will begin. Unfortunately, this will leave many people uncovered and looking for new coverage options available in the Marketplace. People who were covered through Medicaid or CHIP will need to make a transition to a suitable Marketplace qualified health plan or QHP.

However, there is some good news as well. Due to the apparent trouble people will be facing in making this healthcare insurance transition, the CMS has also introduced some flexibilities for states and Marketplaces to avoid any gaps between the converge. People who are losing coverage will be able to get enrolled in a new coverage plan during a special enrollment period announced by CMS, which will start on March 31, 2023, and end on July 31, 2024.

Why is this Special Enrollment Period or SEP important?

The Families First Coronavirus Response Act bound Medicaid agencies not to disenroll people during COVID-19 PHE. But as this Act is expiring, millions of people are likely to lose their healthcare coverage this March. According to an estimation, about 18 million people are at risk of losing their Medicaid coverage once the continuous enrollment policy ends.

However, losing healthcare coverage would be defined as a “qualifying event” that will make one eligible for a SEP. The public health emergency that was in place is ending on April 11, 2023, and if the PHE is not extended (which is expected), you will get a 60-day notice to get enrolled into a new plan. However, this is only applicable to most states using healthcare.gov as their Marketplace. healthcare.gov is implemented in 33 states. The remaining 11 states can provide their own special enrollment period, but they are not bound to do so.

How would this Special Enrollment Period Work?

Among flexibilities introduced by CMS to allow continuity in healthcare coverage for individuals, there is no requirement to submit new documentation for people who are losing their health insurance and buying a new plan. While applying for a new Obamacare plan, the individuals will be asked if they have lost their coverage.

People losing their Medicaid coverage will need to look for a new plan, make a comparison, and choose a plan according to their healthcare needs within 60 days after submitting their application. After selecting a new health insurance plan, the individuals will start to be covered through that plan on the first day of the following month.

Additionally, HHS is streamlining the enrollment process for people losing their coverage during this SEP. previously, individuals were required to submit documentation to provide details of their qualifying event when they were applying outside the open enrollment period or OEP. This will no longer be needed.

How to check the eligibility for the Unwinding Special Enrollment Period?

Marketplace-eligible consumers can benefit from the unwinding SEP by taking the following steps:

• Step 1: start a new application or update an existing one between March 31, 2023, and July 31, 2024
• Step 2: answer YES to the question asking if you have lost or are about to lose your Medicaid or CHIP coverage
• Step 3: provide the date your Medicaid or CHIP coverage is ending (this date should be between March 31, 2023, and July 31, 2024)

The CMS has made this process easier by eliminating any need to submit new documentation. All you need to do is provide an attestation of losing your Medicaid or CHIP coverage to become eligible for unwinding SEP.

According to the CMS recommendations, you should apply for a new coverage plan on healthcare.gov as soon as you get a coverage termination notification from Medicaid or CHIP agency to avoid any gaps in your healthcare coverage.

If you need assistance with finding the right coverage that fits your needs and budget we can help. Our licensed agents can shop around with all the carriers in your area and our services are free for you to use!

The CMS has also taken the following measures to make this process easier for consumers:

• Send notifications to the stakeholders or partners who are in regular contact with or on behalf of the potential consumers
• Offer technical support and training to people involved in the enrollment process, such as agents, brokers, and navigators
• Offer information to the news media to keep the public aware of new changes
• Take measures to directly educate the population about this process by utilizing tools like social media, email, search, and digital video
• Use healthcare.gov as a platform for people who are losing their Medicaid or CHIP coverage and guide them about what steps they should take to continue their healthcare coverage without any delays.

The CMS has implemented adequate measures to ensure the process of enrollment in a new health insurance plan is streamlined for the consumers.

If you need help navigating all your options and finding an insurance plan that fits your needs as well as your budget, contact us today at LIG Solutions and let us assist you through the process. Our services are free for you to use and we have access to all the carriers in your area.