Open Enrollment Year Two: HHS Issues QHP Renewal Game Plan

Hat Tip To: 
Steve Ciccarelli

Not sure how I missed this yesterday; thanks to Steve C. for the heads' up:

The Obama administration on Thursday plans to issue much-anticipated instructions for Americans to reenroll for next year in the new federal health insurance marketplace — a set of rules intended to make it easy for consumers but that nevertheless will require some people to reapply through to preserve their subsidies or coverage.

Under the rules, people will need to do very little to remain in their health plans if their incomes and covered family members are not changing and their plans are offered again for 2015.

Yeah, I (and everyone else) have been wondering about this. I didn't know if everyone who was enrolled in a QHP would have to manually renew their enrollment (which would be a royal pain in the tush, but would actually make my job somewhat easier, in terms of tracking the total number of people signing up, whether they were already part of the 8.5 million & counting or not), or if it would only apply to those whose situation has changed.

According to the WaPo, it looks like it's the latter...with a few caveats:

A fraction of the people in the federal insurance exchange will need to reapply for one or more reasons: their incomes are rising or falling significantly, they did not give permission for their tax records to be checked automatically, or the health plans they joined this year disappear as of January.

Later on, they explain that the "tax record permission" thing only applies to around 100K people, but it's impossible to know how many people's incomes will "rise or fall significantly". Hell, I may very well fall into this category; both my wife and I are self-employed in a business with wide income swings year to year, and this year in particular is likely to be a weird one.

There's an estimate that the total number who will have to reenroll will only be about 5% (500K, if you assume around 10M total enrollees as of 11/15), but that sounds pretty low to me, considering that a good 200K - 300K people per month are still enrolling for the first time even during the off-season...due to major life changes including signfiicant changes in income and so forth.

In addition, people are still having those "Qualifying Life Events" (giving birth, getting married/divorced, moving to a different state, etc) during the open enrollment period as well!

Personally, I suspect that the 5% estimate is way too low; I'd guess it'll end up being more along the lines of 20-25%.

As an aside, I also question the wisdom of not requiring everyone to re-enroll each year. Obviously HHS is trying to minimize the inconvenience/hassle factor, but it seems to me that this is just going to cause even greater confusion than it would if they simply issued a blanket statement: If you enrolled via an ACA exchange, you have to renew once a year even if nothing else has changed.

I don't see doing this as a big deal; people have to renew their license plates every year even if it's for the same car, for example. They don't have to make it that complicated...just have big Yes/No radio buttons once you log in that says "Have you had any significant changes in (income, dependents, etc...provide a list) since (date of existing policy enrollment)?" If no, then you click "Save" and you're done. If yes, then you go ahead and make whatever changes are necessary.

On a related note, there was a lively discussion on Twitter this morning between healthcare policy heavyweights Caroline Pearson, Paul Houchens, Adrianna McIntyre, Larry Levitt and others about the confusion regarding how the tax subsidies will change this year, since the formula is based in part on the cost of the lowest-cost Silver plan...which itself will be changing. This conversation is way out of my league, but I'd advise people to check it out, could be messy...