Open Enrollment Starts Saturday, November 15: The second open enrollment period for the health insurance marketplaces (OE2) will start on Saturday, November 15 and run through February 15, 2015. People who already enrolled in OE1 should still take action in OE2 to make sure they maintain the right amount of financial help and are enrolled in the plan that best meets in their needs. New and returning consumers should enroll or switch plans by December 15 for coverage starting on January 1. All consumers will be able to apply for coverage online, by phone (1-800-318-2596), by paper application, or with in-person assistance.
Consumers Can Start Comparing Health Insurance Plans Before November 15: Some marketplaces have launched “window-shopping” features that allow consumers to estimate the financial help they could qualify for and compare 2015 plans available in their area — without needing to create an account or submit an application:
- Federally Facilitated Marketplace (FFM): On November 9, HealthCare.gov launched its window-shopping tool with information on plans for 2015.
- State-Based Marketplaces: Consumers in California, Colorado, Idaho, Maryland, Rhode Island, and Washington can now use window-shopping features. Current enrollees in California can also now renew their coverage for 2015 before OE2 starts.
Health and Human Services (HHS) Releases Report on Projected Marketplace Enrollment: On November 10, HHS released a report projecting that 2015 total effectuated marketplace enrollment will reach 9.0-9.9 million. The estimate includes 5.9 million consumers renewing coverage and 3-4 million seeking new coverage. The report’s projections are lower than Congressional Budget Office (CBO) estimates because HHS expects a higher rate of employer-sponsored insurance coverage and a longer ramp-up period before marketplace enrollment reaches a steady year-to-year level. The report also gave an updated point-in-time enrollment figure for October, which saw 7.1 million consumers enrolled in marketplace coverage. This figure includes consumers who had enrolled through Special Enrollment Periods since OE1 ended, in addition to enrollees who had paid for and retained their coverage since OE1. The last point-in-time enrollment count was slightly higher, with 7.3 million enrolled in August.
Supreme Court Will Hear Legal Challenge to Tax Credits in FFMs: On November 7, the Supreme Court agreed to review King v. Burwell, a legal challenge regarding whether enrollees in FFM states are allowed to receive tax credits under the Affordable Care Act (ACA). The Fourth Circuit Court of Appeals had previously held unanimously in this case that such FFM enrollees were eligible to receive premium tax credits, and the D.C. Circuit Court of Appeals vacated an earlier judgment holding that tax credits could not be provided to FFM enrollees. As the Supreme Court will not hear this decision until next spring, there is no immediate impact on consumers. Current enrollees get to keep their tax credits, and those renewing their coverage and signing up for the first time during OE2 will be able to receive financial help as this judicial process continues.
New Guidance on Minimum Essential Coverage for Limited Medicaid Coverage: In guidance issued on November 7, the Centers for Medicare and Medicaid Services (CMS) and the Internal Revenue Service (IRS) clarified that certain types of Medicaid and Children’s Health Insurance Program (CHIP) coverage are not considered minimum essential coverage for the purposes of eligibility for premium tax credits and cost-sharing reductions, but that those enrolled in these Medicaid programs will also be eligible for an hardship exemption from the fine for not having health coverage. In other words, individuals enrolled in certain types of Medicaid/CHIP coverage — including pregnancy-related Medicaid, pregnant women receiving CHIP coverage for their unborn children, and coverage for the “medically needy” — can receive financial help purchasing coverage through the marketplace but will not be subject to the fine if they do not do so. CMS will release additional guidance about how these individuals can receive the fine exemption.
FFM Enrollees Should Inform Insurer After Switching Plans During OE2: Since marketplace insurers will not receive any notification from the FFM when a current enrollee chooses not to renew their plan, consumers should contact their 2014 insurer to inform them that they are not renewing the plan for 2015, as well as stop any auto-payments they have set up. This guarantees that the consumer will not be auto-renewed into a plan he/she does not want, which could leave them double-enrolled (and double-billed) in their new and old marketplace plans at the same time.