Idaho: Hmmmm...Your Health Idaho waives coverage loss documentation for employer coverage loss SEP

Back on March 23rd, I noted that while every other state-based ACA exchange has launched an official COVID-19-specific Special Enrollment Period, there are two ACA exchanges which have refused to do so. One of them is the mothership, HealthCare.Gov, which is run by the Centers for Medicare & Medicaid (CMS) and which hosts a whopping 38 states. The other one is Your Health Idaho:

I contacted the exchange last week to see what the deal was re. a COVID-19 SEP and they kicked the ball over to the state Insurance Dept:

COVID-19 (coronavirus) is not currently considered grounds for a Special Enrollment Period in Idaho. Questions around the potential offering of an SEP would be best answered by the Idaho Department of Insurance. This really falls within their regulatory authority. YHI will follow their guidance and support whatever decision is made.

I did indeed contact the Idaho DOI, but I didn't hear back from them until today. Here's what they had to say:

Thank you for reaching out. We are continually monitoring the situation daily under the direction of Idaho’s Office of the Governor. While it is our understanding that a diagnosis of a disease is not currently criteria for a Special Enrollment Period, we are aware that there is national discussions about adding one regarding COVID-19. Idaho is in a somewhat unique situation in that two health insurers are offering individuals in Idaho an ongoing enrollment option with the fully-comprehensive Enhanced Short Term Plans, so anyone who wishes to purchase major medical coverage today can obtain it. We will continue to assess, and have not ruled out any future actions.

As I explained, in most states, so-called "short-term, limited duration" healthcare policies are pretty crappy, with medical underwriting, low caps on coverage, lots of loopholes and coverage exemptions and so forth. In a few of the remaining states they've been banned outright or restricted so that they can only be enrolled in for up to 3 months per year (which makes sense; that's why they're called "short term, limited duration"). In Idaho, they've decided to sort of split the difference, by selling "enhanced" short-term plans:

In other words, they sort of split the difference between traditional #ShortAssPlans and fully ACA-compliant Qualified Health Plans (QHPs). STLDs can have stingy annual limits; QHPs can't have any; "enhanced" STLDs have to have a minimum of $1 million. STLDs don't have guaranteed issue or community rating; QHPs have both; "enhanced" STLDs have the former but not the latter, and so on.

Again, this is a very slippery slope (especially the idea of offering them alongside QHPs on the exchange), but for good or for bad, they're a thing in Idaho at the moment.

This is obviously better than nothing, but it's also a far cry from a full COVID-19 Special Enrollment Period for at least two reasons:

  • First, normal SEPs are only allowed for uninsured residents who have had a Qualifying Life Experience (QLE) such as losing their current coverage, moving, getting married/divorced, having a child and so on. A "full" COVID-19 SEP is open to any uninsured resident (as long as they 're a U.S. citizen).
  • Second, normal SEPs require full documentation of your QLE (uploading a termination of coverage notice, marriage certificate, birth certificate, etc.) and verification of such by the exchange (which could take weeks or even months depending on the backlog).

As both my friend Andrew Sprung and I explained a couple of weeks ago, this second point is a recipe for disaster under the current situation:

That's six million people who are going to be desperately scrambling to jump through all of the hoops which CMS is placing in front of them for no legitimate reason whatsoever.

That's one hundred times the number of people who would typically enroll in "lost my coverage" SEPs via HealthCare.Gov in a typical two-week period.

...Imagining current predicaments, Quenga posits, "You can't just go into your place of business and talk to them because the business is closed. "Your own supervisor may have been laid off. So who are you supposed to talk to?"

Once the termination date has been nailed down and an application started, the 30-day window to provide documentation begins (meanwhile, the applicant still lacks coverage). "Insurance companies typically don't provide the certificate of creditable coverage until your coverage has actually ended, and that usually takes two weeks if they're coming by snail mail," Quenga says.

There's even a petition being circulated by Reclaim Idaho, the ID-based activist organization which was the engine behind the state's successful Medicaid expansion movement in 2018, to get the state to launch a formal, official COVID-19 SEP:

Call on Governor Little to Open Idaho's Healthcare Exchange

As jobless claims are soaring due to COVID-19, thousands of Idahoans are in desperate need of healthcare coverage. Medicaid Expansion is providing relief for many, but not for all. For thousands of people, there is only one option: Idaho's healthcare exchange.

But here's the thing: The enrollment period for Idaho's healthcare exchange ended in December, months before the outbreak of COVID-19. This means that thousands of Idahoans are being shut out from healthcare coverage in the midst of a global pandemic.

Fortunately, Governor Brad Little has the power to follow other states and open Idaho's healthcare exchange for a Special Enrollment Period. In fact, Idaho's exchange is the only state-run exchange in the country right now that is not open for enrollment.

Please sign the petition and call on Governor Little to open Idaho's healthcare exchange.

Well, the pressure appears to be getting to the powers that be in Idaho (or at least some of them), because Louise Norris just called my attention to this local paper Op-Ed written by the Executive Director of Your Health Idaho:

Op-Ed: Your Health Idaho Working to Ease Access to Health Insurance amid COVID-19 Pandemic

Impacts from COVID-19 (coronavirus) continue to spread throughout our communities and around the world. As we grapple with this new reality, Your Health Idaho remains committed to serving Idahoans by providing a path to health insurance coverage when the need is greatest.

At a time when the overall health and well-being of our collective population is the top priority, Your Health Idaho is working hard to help Idahoans who have been impacted by COVID-19, specifically those who now find themselves out of a job and without health benefits.

In partnership with the Idaho Department of Insurance and Idaho insurance providers, and in alignment with Governor Little’s initiative to reduce regulations, Your Health Idaho is working to relax the requirements for eligible Idahoans to enroll in coverage.

Idahoans who have lost employer-sponsored health insurance as a result of termination, layoff, or furlough due to COVID-19 are eligible for a Special Enrollment Period. Previously this process would require several steps of documentation and validation. Under the newly relaxed policy, in lieu of documentation and proof of termination, Idahoans can now submit a written statement explaining their loss of employer health benefits. This new process removes time-consuming barriers and ensures an expedited path to coverage.

In other words, they're not actually launching an "open" SEP for anyone whose uninsured as the other 12 state exchanges are, but they are mostly crossing out the second bullet I listed above: The documentation/paperwork part.

I'm not sure how I feel about this. Letting people jot down a short note based on the honor system is certainly an improvement, but it still only addresses the unique situation a pandemic presents partway. Also, when I checked the YHI website, I don't see this new policy displayed there yet (the Op-Ed is from 4 days ago). The "Loss of Coverage" SEP page still lists documentation being required, and even the COVID-19 FAQ page doesn't say anything about it yet, so I'm not sure if they're just ramping it up now or what.

Still...it's something. Also, YHI's Op-Ed makes another important point about the benefits of states operating their own full ACA exchanges:

One of the many benefits of an Idaho-run insurance marketplace is the ability to adapt and respond quickly. By continuing to do things the Idaho way, we can assess the needs of Idahoans and implement solutions that are right for our state and our communities.

UPDATE 4/20: OK, YHI has updated their SEP pages to clarify the new policy, and they've also posted this press release:

If You Need Health Insurance, Your Health Idaho is Here to Help

Impacts from COVID-19 (coronavirus) continue to spread throughout our communities and around the world. As we grapple with this new reality, Your Health Idaho remains committed to serving Idahoans by providing a path to health insurance coverage when the need is greatest.

At a time when the overall health and well-being of our collective population is the top priority, Your Health Idaho is working hard to help Idahoans who have been impacted by COVID-19, specifically those who now find themselves out of a job and without health benefits.

In partnership with the Idaho Department of Insurance and Idaho insurance providers, and in alignment with Governor Little’s initiative to reduce regulations, Your Health Idaho is working to relax the requirements for eligible Idahoans to enroll in coverage.

How To Enroll?

Idahoans who have lost employer-sponsored health insurance as a result of termination, layoff, or furlough due to COVID-19 are eligible for a Special Enrollment Period. Previously this process would require several steps of documentation and validation. Under the newly relaxed policy, in lieu of documentation and proof of termination, Idahoans can now submit a written statement explaining their loss of employer health benefits. This new process removes time-consuming barriers and ensures an expedited path to coverage.

Unsure If You’re Eligible?

While we are hopeful that the updated requirements will simplify the process of gaining coverage, we also know that the world of health insurance can be confusing in the best of times, let alone during a global pandemic. For that reason, we encourage all Idahoans, even those who are unsure if they are eligible, to work with an insurance agent or broker. These dedicated professionals are licensed by the Idaho Department of Insurance and complete annual training through Your Health Idaho. Their expert advice is free of charge. To search for help in your area, visit YourHealthIdaho.org/find-help.

Over the last seven years, the Your Health Idaho mantra has always been business as usual. Meaning that no matter what challenges we face, we must stay focused on our mission to maintain maximum control of the state’s health insurance marketplace at minimal cost to its citizens. And while our core mission remains the same, navigating the COVID-19 pandemic is not business as usual. Instead, we see it as conducting the business of serving Idahoans in highly unusual times.

What Steps Are Your Health Idaho Taking?

As Your Health Idaho works to prioritize access to coverage for Idahoans, we, like many businesses, have also had to adjust how we serve our customers. To protect the health and safety of our employees, the Your Health Idaho team is working remotely and supporting customer needs primarily through electronic communication. This change comes with additional challenges, but Your Health Idaho has implemented several new resources for Idahoans including; a COVID-19 and Your Health Idaho webpage with FAQs and contact information, a web-based Customer Support Request Form to expedite email communication and limited phone support at 1-855-944-3246. Your Health Idaho will continue to evaluate how to best serve our customers during this unprecedented time.

One of the many benefits of an Idaho-run insurance marketplace is the ability to adapt and respond quickly. By continuing to do things the Idaho way, we can assess the needs of Idahoans and implement solutions that are right for our state and our communities.

We’re Here For You

Your Health Idaho remains steadfast in our commitment to serving Idahoans—our friends and neighbors. We will get through this. Together.