At Enroll America, we work every day to make health coverage enrollment a part of the fabric of communities across the country. As part of this work, we have consistently emphasized the importance of helping consumers understand the intersection between health coverage and their taxes (whether they got covered and are getting financial help, or remain uninsured) and how to successfully navigate the tax filing moment. And when the Centers for Medicare and Medicaid Services (CMS) announced a tax filing Special Enrollment Period (SEP) from March 15 through April 30, 2015, we urged the enrollment community to seize the opportunity to highlight financial help and capitalize on the real impact of the fine to motivate uninsured consumers to take action.
In preparation for the third open enrollment period (OE3), Enroll America is releasing a new issue brief — Amplifying the Connections Between Health Coverage Enrollment and Tax Filling — that draws on public data, as well as Enroll America’s private survey research and outreach efforts, to make specific recommendations for policymakers and other enrollment stakeholders on how to best leverage the tax filing moment. Specifically, we are asking that policymakers move swiftly to make several improvements (two of which are below) that would benefit consumers for both this upcoming tax filing season and beyond:
1. In 2016, create an SEP between February 1 and April 30 for consumers facing the fine for not being covered in 2015.
2. In 2017 and beyond, set the annual marketplace open enrollment period dates as November 15 to March 15, while maintaining the January 1 start to coverage year. (The open enrollment period [OE] dates for 2017 and beyond have not been finalized.)
These recommendations, and indeed any decisions surrounding when consumers can sign up for marketplace coverage, undoubtedly will require certain trade-offs, which the enrollment community should explore over the next few months, together, so that we can, find a solution that best meets the needs of consumers.
While we are recommending that OE be November 15 to March 15 for 2017 and beyond, there are other options that should be evaluated, such as a shorter OE in late fall or spring, or strategically setting a tax filing SEP through mid-April following an OE that runs from mid-November to mid-February. Here are some important considerations that can help inform these conversations moving forward:
- Stretching OE from November 15 through March 15 will capitalize on the ability to magnify the significance of the fine, broaden the availability of in-person assisters (including from tax preparation organizations), and reach more than half of the total number of consumers who claim refunds when filing their tax returns. Also, there are benefits in allowing consumers to sign up for coverage after the saturation and financial stresses associated with the holiday season end. One could similarly capitalize on these advantages to maximize enrollment by appropriately providing a tax SEP following the close of OE.
- An OE from November to March may stretch capacity, and setting a shorter OE in the fall would align marketplace enrollment with Medicare and most employer plans. This would position many families to make all their choices about their health coverage at the same time to get January 1 coverage.
- Moving OE to start in February to align more fully with tax filing season and switching to a non-calendar plan year starting in May takes advantage of similar dynamics of our recommendations above. But this would also entail administrative burden associated with a transitional period to shift from the current calendar-year structure.
To learn more about our recommendations and analysis related to the connections between health coverage enrollment and tax filing, make sure to read the full issue brief here.