As Special Enrollment Periods Evolve, Don’t Forget Remaining Uninsured

By Anne Filipic

This column was originally published in Morning Consult.

As the Department of Health and Human Services is in the process of implementing new documentation requirements for consumers to enroll in Marketplace coverage through Special Enrollment Periods (SEPs), there has been a great deal of discussion among stakeholders about how to ensure the integrity of the system while making sure consumers don’t have to jump through too many unnecessary hoops to access this important path to coverage.

The concern at the root of this discussion is one of risk pools. And this is something all of us working in health care need to care about. Diverse pools mean lower costs not only for insurers, but also for consumers. So as the SEP debate continues, it’s critical that the coalition doesn’t lose sight of the big picture questions: how do we ensure that marketplace coverage remains accessible and affordable for all eligible consumers for years to come, and maximize the opportunity with the remaining uninsured who have yet to experience the value of health insurance?

At Enroll America, we share the goal of limiting abuse of SEPs. Traditional enrollment periods exist for a legitimate reason – to help protect against moral hazard and keep costs down for all.

At the same time, we believe that placing undue verification or documentation burdens on consumers may actually prevent eligible people from enrolling. And if we make the SEP process too difficult, it could mean that only those that have the greatest incentive to get covered, e.g. those who have the greatest health care needs, will actually make it all the way through to enrollment. This would have the opposite of the intended effect on the risk pool.

Numbers show SEPs are already underutilized. According to the Urban Institute, even though nearly 13 million uninsured people every year could gain health coverage through SEPs, only about 15 percent actually sign up. The truth is that we need to continue to make sure that people – including young and healthy people – are aware of SEPs, and that those that are eligible, can take advantage of their new coverage options. We’ve recommended some ways HHS can employ consumer-friendly principles to make sure that this happens.

But even as we work with policy makers, insurers, and consumer advocacy organizations to find the best solutions around Special Enrollment Periods, it’s critical that we don’t lose sight of the broader goal to continue to expand the roster of enrollees and bring more and more people into the system using outreach tactics we know that work, including young and healthy individuals who may still be sitting on the sidelines.

Based on findings from a recent report by the Urban Institute and the Robert Wood Johnson Foundation, there are 12.4 million uninsured individuals who are particularly moveable – 9.1 million of whom are eligible for free or low cost coverage through Medicaid or CHIP and an additional 3.2 million who have incomes below 200 percent of poverty, and are therefore eligible for marketplace coverage with premium assistance and significant help with their out-of-pocket costs. We know that affordability is the number one issue for consumers, and that it is the driving factor behind individuals getting covered and staying covered.

This audience represents a critical group who will see great personal benefit from the security that comes from having health coverage. Enroll America is continuing to refine our strategies and work with the broader enrollment community to ensure that we can reach these individuals with the information they need to take action. Having more people enter the marketplaces will not only help stabilize the market, but will attract even more plans and increase competition, which can help keep costs down for consumers.

SEPs are an important piece of the puzzle and they provide critical opportunities for consumers to gain access to coverage as they experience major life changes. But SEPs are only one piece of a much broader strategy. As we consider how we can continue to build a strong marketplace system that works for consumers and meets their needs in the long term, we must continue our work to reach the remaining eligible uninsured, particularly the consumers that are most moveable, and support them through the enrollment process.

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