New Hampshire: All 3 #ACA exchange carriers will offer deductible & OOP credit for COVID SEP plan switchers

A couple of weeks ago I noted that all 11 California health insurance carriers participating on the state's ACA exchange, CoveredCA.com, have agreed not to reset deductibles for current off-exchange enrollees who shift to an on-exchange plan during the ongoing COVID Enrollment Period.

This is a HUGE deal, especially in California, where an estimated 430,000 residents are enrolled in off-exchange ACA policies which are virtually identical to their on-exchange equivalent, with the sole distinction of those enrolled in them not being eligible for ACA subsidies.

With subsidies being beefed up and the 400% FPL subsidy cliff having been killed (for the next 2 years, at least), this means that hundreds of thousands of Californians have just become eligible for thousands of dollars in savings...as long as they transition to the same plan on-exchange.

The only downside of doing so, besides the minor procedural hassle of creating a CoveredCA.com account and making the transition, is that some of these folks may have already racked up thousands of dollars in deductible, co-pay or coinsurance payments by the time they make the move. Normally, all of that would be reset by shifting to a different policy...even if it's different in code number and exchange status only.

However, by agreeing to make the deductibles "passthru" from off- to on-exchange, California insurers just eliminated the only significant reason not to make the move.

(I should note that the CA press release doesn't mention anything about co-pays or coinsurance being passed thru, but deductibles likely comprise the vast bulk of any baked-in 2021 expenses anyway).

Well, moments ago I received the following bulletin from the New Hampshire Insurance Dept.:

All Three Health Insurers on Healthcare.gov Will Offer Deductible and Out-of-Pocket Expense Credits for Plan Changes

CONCORD, NH - The New Hampshire Insurance Department announced today that all three health insurance companies offering plans on the Health Insurance Marketplace (Healthcare.gov) will offer deductible and out-of-pocket maximum expense credits for consumers who want to change plans within the same company due to increased affordability options as a result of the American Rescue Plan. The Department coordinated with Ambetter by NH Healthy Families, Anthem, and Harvard Pilgrim to resolve a deductible and out-of-pocket maximum re-set issue that would have occurred if consumers selected a different plan within the same company.

From April 1 to August 15, consumers can enroll for the first time, or resubmit their application on Healthcare.gov, to take advantage of lower monthly premiums and out-of-pocket expenses. All consumers who currently have a plan through Healthcare.gov are strongly encouraged to visit the website and reprocess their application. For many, this will generate the increased premium tax credit amounts that can be allocated toward the plan cost.

“This is an important resolution for Granite Staters that may be shopping for more affordable options on Healthcare.gov during the extended open enrollment period,” said Governor Chris Sununu. “I want to commend Ambetter, Anthem, and Harvard Pilgrim for providing these customer friendly protections proactively so that no one will lose the money they have already spent on their health care in 2021. This will extend more choice to New Hampshire residents who may want to select a plan with enhanced benefits as a result of lower costs.”

It's important to note that New Hampshire's press release is not the same thing as California's. CA's PR refers to people shifting from off-exchange policies to on-exchange policies. New Hampshire is talking specifically about those currently enrolled in on-exchange policies who take advantage of the unusual Special Enrollment Period to switch to a different on-exchange policy (as long as it's from the same insurance carrier, of course).

In other words, let's say someone's currently enrolled in a Bronze plan from Anthem, and they decide to upgrade to Silver thanks to the enhanced subsidies. They've already used up $1,000 of their $6,000 deductible (or whatever). As long as they switch to another on-exchange Anthem plan, Anthem will carry that $1,000 over to whatever the Silver deductible is. Obviously they won't do that for someone switching from an Ambetter or Harvard Pilgrim plan, which is reasonable.

This is still a Big Deal, and it'll be interesting to see how many other states or individual carriers offer something similar, either for current exchange enrollees, off-exchange enrollees or both.

According to the U.S. Department of Health and Human Services, 22,900 uninsured New Hampshire residents are newly eligible for premium tax credits under the law and 1,000 uninsured residents are now eligible for $0 silver benchmark plans.

“Whether you are uninsured or already have an individual plan, it has never been more affordable to buy health insurance in the Granite State,” said Insurance Commissioner Chris Nicolopoulos. “I strongly encourage everyone who qualifies for individual health coverage to visit Healthcare.gov and submit or reprocess their application so they can take advantage of increased premium subsidies and lower costs, and thanks to Ambetter, Anthem, and Harvard Pilgrim, everyone will be able to shop within their current company without fear of losing what they have already spent.”

In addition, many people who already have health plans purchased through Healthcare.gov will qualify for enhanced premium tax credit amounts and reduced out of pocket costs. Premium assistance will also increase for individuals above 400% of the Federal Poverty Level (FPL), because the law has decreased the percentage of household income that must be contributed toward a health plan.

“I want to thank New Hampshire’s three individual health insurance carriers on delivering this consumer friendly result,” said Deputy Commissioner D.J. Bettencourt. “This is a great opportunity for individuals and families to take advantage of the additional premium assistance and shop around to find the best plan for them. As long as they stay with the same company, they will be able to keep what they have expended out-of-pocket for the rest of the plan year.”

Premium savings will be applied retroactively to those months in 2021 prior to reprocessing the application and will be repaid when consumers reconcile their 2021 taxes. If no action is taken during the extended Special Enrollment Period, consumers will receive their premium savings as a 2021 tax refund.

The American Rescue Plan also extends affordability to those receiving unemployment benefits. If someone receives unemployment compensation. Consumers with unemployment compensation can revisit their application to receive additional financial subsidies. Beginning in early July, these individuals who were determined eligible for unemployment for any week during 2021 may be able to get an additional increase in savings when enrolling in a plan or reprocessing their application. More information on these benefits will be forthcoming.

Consumers seeking assistance with the enrollment process can get free help from an insurance agent, federal Navigator, or enrollment assister using the Find Local Help tool on Healthcare.gov or by contacting NH Navigator by calling 1-877-211-NAVI or by visiting their website.