Navigating Enrollment Challenges on the Road to January 1, 2014.

Health Reform Watch

Volume 9, December 4, 2013
Following significant glitches with the rollout of the federal health reform website (, the federal government has worked over the past month to fix the website and has continued to release guidance to troubleshoot problems and ensure consumers can enroll in time for the January 1, 2014 coverage effective date. In the meantime, state implementation continues as hundreds of thousands of people around the country apply for new coverage. The most recent federal and state updates as well as health department implementation highlights are discussed in detail below.
NASTAD is always interested in hearing about specific state processes to prepare for health reform. Please contact Amy Killelea to share activities or specific documents that have been created. We are in the process of creating a webpage to better share these documents. 

In This Edition


From the NASTAD Blog: The Most Recent Health Reform Posts

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AIDS Drug Assistance Program (ADAP) Alerts

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Federal Implementation Updates

Deadline for Plan Enrollment Extended
  • ACTION STEP: Ensure that clients and outreach and enrollment counselors understand when to enroll in coverage and actions and deadlines for a January 1st coverage effective date.

In November, the Department of Health and Human Services (HHS) announced that the deadline for signing up for a Qualified Health Plan (QHP) with a coverage effective date of January 1, 2014 will be extended to December 23, 2013 (the previous deadline had been December 15, 2013). This means that clients have until December 23 to complete the QHP application process and enroll in a plan. This extension may be particularly important for clients currently on Pre-Existing Condition Insurance Plans (PCIPs) or state high risk pools that are ending on December 31, 2013 and who need to transition to new coverage by January 1, 2014. The extension is in recognition of the problems many people have been having in accessing and completing online applications. However, programs and consumers should keep in mind that coverage cannot begin until the plan receives the first premium payment, and plans may require this payment be received prior to the coverage effective date. These important dates are captured below:

Dates for Enrollment and Coverage
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2014 Open Enrollment Dates Extended

  • ACTION STEP: Ensure that clients and outreach and enrollment counselors understand open enrollment dates.

In another announcement in November, HHS extended the open enrollment period in 2014. Instead of an open enrollment period running from October 15, 2014 to December 7, 2014 (aligned with the Medicare open enrollment dates), open enrollment will begin on November 15, 2014 and end on January 15, 2015. This extension does not impact the current open enrollment period, which runs from October 1, 2013 through March 31, 2014.

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Administration Announces Transitional Policy for Cancelled Individual Health Plans

  • ACTION STEP: Monitor plan options for clients covered in individual markets and ensure clients who need to transition to new plans understand options and how to apply.

In response to a significant number of issuers in the individual market cancelling coverage for current members in January 2014 (when many new insurance regulations go into effect, including Essential Health Benefits coverage requirements), the Centers for Medicare and Medicaid Services (CMS) Center for Consumer Information and Insurance Oversight (CCIIO) issued a transitional policy for individuals and small businesses that had received a cancellation notice. Health insurance issuers may choose to continue coverage that would otherwise be cancelled for an additional year. Importantly, state authorities must approve this transitional policy, and several states have announced they will not allow cancelled policies to be re-sold for 2014 plan years (see map developed by America’s Health Insurance Plans (AHIP) for state decisions). Issuers must notify enrollees about which market reforms will not be reflected in the plan, the enrollee’s option to enroll in a Qualified Health Plan (QHP) through a Marketplace, how to access coverage through the Marketplace, and plan options outside of the Marketplace that comply with market reforms.

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Administration Works with Insurers to Allow Consumers to Sign up for Plans Directly through Plan Websites

  • ACTION STEP: Ensure that clients enrolling directly with plans understand how to also apply for premium tax credits and cost-sharing reductions.

In response to the issues with the website, HHS worked closely with issuers to allow applicants to compare and apply for QHP coverage directly through issuer websites rather than through HHS is currently working to allow issuers to access the federal data services hub, which would allow issuers to screen consumers for federal subsidy eligibility, and that ability is expected soon.

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Administration Issues Final Mental Health Parity Rule

  • ACTION STEP: Ensure that programs and clients understand new rights regarding access to mental health and substance use disorder services.

In November, HHS released a much-awaited final rule implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act. While they do not mandate coverage of mental health and substance use disorder services, the law and implementing regulation ensure that health plan cost sharing, treatment limits, and other plan design features are not applied more restrictively for mental health and substance abuse disorder benefits than for medical benefits. In addition, plans must have transparent processes for coverage determinations to ensure that criteria for service denials are not more stringent for mental health and substance use disorder services than for medical treatment. The final rule makes several additional clarifications, including applying parity requirements to provider networks (e.g., standards for admission into the network cannot be more restrictive for mental health and substance use disorder providers) as well as applying parity requirements to the entire scope of services offered (e.g., if a plan covers rehabilitation, case management, and other support services for medical care, it cannot have more stringent restrictions for comparable support services coverage for mental health and substance use disorder services). The parity requirements apply to most commercial plans, including plans sold through the Marketplaces starting in January 2014. Additional regulations on application of the parity law to Medicaid expansion benefits are forthcoming. See National Alliance of Mental Illness (NAMI) for more resources.

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State Implementation Updates

Marketplace Rollout

  • ACTION STEP: Monitor implementation of state-run Marketplaces, including best practices.

State-run Marketplaces are faring somewhat better than their federally run counterparts, with hundreds of thousands of people applying for coverage over the first two months of open enrollment. Robust outreach and enrollment efforts combined with web portals that have, for the most part, avoided the technical glitches of the federal site, have all contributed to a successful launch in these states. Moving forward, many of the state-run Marketplaces may have more flexibility than their federal counterparts to develop consumer friendly processes and to tailor systems to state-specific needs. States like Washington – which is already working with ADAP and other programs to coordinate premium payments to plans on behalf of the program – will provide useful lessons and best practices as ACA implementation continues.

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Health Department Updates

Preparing for Qualified Health Plan (QHP) Coverage

HIV/AIDS and viral hepatitis programs are preparing for transition to QHP coverage starting in January 2014 for many clients. As programs work to manage this transition in ways that ensure uninterrupted access to care, they are considering:

  • Prioritizing transition of clients currently receiving care through Pre-existing Condition Insurance Plans (PCIPs) or state high risk pools ending on December 31, 2013.

    Recently announced extensions of application deadlines have not extended the life of PCIPs or many state high risk pools, which are closing at the end of 2013. In order to ensure uninterrupted access to insurance coverage for clients currently receiving care through these plans, clients must be enrolled in new QHP coverage by December 23rd. HIV/AIDS and viral hepatitis programs are working around website glitches and difficulty obtaining plan information to ensure that this population is able move into new coverage starting January 1st, 2014.
  • Working across Ryan White Program Parts and providers to ensure that clients transitioning to QHPs are able to meet medical co-pay and other cost-sharing obligations.

    As clients move into QHP coverage, they may have co-pay and other cost-sharing obligations for the first time, presenting a significant barrier to accessing care and treatment. While many Part B insurance purchasing programs are able to pay premiums and prescription co-pays on behalf of clients, payment of medical co-pays is more difficult for the state to administer. However, other Ryan White Program Parts are also able to pay medical co-pays on behalf of clients. In a number of states, grantees are working collaboratively across parts – including with Part A and Part C grantees – to ensure that where the state insurance purchasing program does not or cannot pay medical co-pays on behalf of clients, other providers are providing this crucial assistance.
  • Working closely with case managers and contracted agencies to develop and announce new health department policies.

    In order to prepare case managers and contracted agencies for ACA implementation, many state HIV/AIDS programs have facilitated all-day trainings for these groups. These trainings have two purposes. The first is to provide detailed information and updates about ACA rollout and plan options in the state. The second purpose is to facilitate dialogue and feedback on ADAP/Part B policies moving forward with regard to plan selection, outreach and enrollment, and insurance purchasing coordination. NASTAD has facilitated several of these trainings; for information on how these trainings are structured and examples of state training resources, contact Amy Killelea.

Coordinating Premium Payments with Marketplace

In preparation for transition of many ADAP clients into QHPs through the Marketplaces, Ryan White Program insurance purchasing programs are preparing systems and processes to ensure efficient payment of premiums on behalf of clients. For instance, the Washington insurance purchasing program has worked closely with the state-run Marketplace to become a designated “sponsor” entity. Sponsors – which can be city and county governments, Indian tribes, tribal organizations, urban Indian organizations, private foundations – are permitted to pay premiums on behalf of qualified enrollees directly to the Marketplace (rather than to individual plans). The Washington insurance purchasing program worked closely with key Medicaid contacts to facilitate initial dialogue with both Marketplace policy makers and other sponsors (primarily Indian tribes). Insurance purchasing program staff and the program’s insurance benefits manager participated in sponsorship trainings as well as stakeholder meetings as the policies and procedures were developed. The first payment will be made electronically to the Marketplace on December 23, 2013 and will consist of individual payments (the Marketplace will not allow bulk payments for all clients). The insurance purchasing program will have access to regular reports once payments begin.

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Health Reform Resources

For questions or for suggestions for NASTAD health reform resources that would be helpful to your program, please contact Amy Killelea.

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