Connecticut: @AccessHealthCT changes policy, will allow current exchange enrollees to switch plans during upcoming SEP after all

A week or so ago, Access Health CT's COVID Special Enrollment Period ended...but they also announced that they're re-launching a new SEP starting on May 1st anyway. This amounts to them taking a 2-week pause to reprogram/retool their website to take advantage of the expanded ACA subsidies under the American Rescue Plan.

At the time, they were only allowing current exchange enrollees to switch plans mid-year via a cumbersome process of calling into the exchange directly. Today it sounds like that's been changed:

Access Health CT American Rescue Plan Act Policy

Background
The American Rescue Plan Act signed into law on March 11, 2021 includes provisions that make more consumers eligible for the Premium Tax Credit (PTC) and increases the amounts of PTCs for calendar year 2021 and 2022.   The required contribution percentages for consumers used to calculated PTCs are now reduced to lower levels, and those with annual income up to 150% of the Federal Poverty Level (FPL) have 0% required contribution percentage toward the Essential Health Benefit (EHB) portion of premium, a 2% required contribution percentage at 200% of the FPL up to a maximum of 8.5% required contribution percentage at 400% of the FPL.  The eligibility cap at 400% of the FPL has been removed for calendar years 2021 and 2022, allowing consumers with incomes above 400% of the FPL to also be eligible to receive PTCs for the first time.  Consumers may wish to change to a different plan to take advantage of this new financial assistance, and consumers not currently enrolled in a plan through the Exchange may wish to enroll now to access this new financial assistance.

Policy
The ACA provides for Special Enrollment Periods (SEP) for eligible consumers outside of the annual Open Enrollment Period when a consumer experiences a qualifying life event pursuant to 45 CFR 155.420.  Exchanges may permit consumers or enrollees to access a SEP due to exceptional circumstances, 45 CFR 155.420(d)(9), and Access Health CT has determined that the changed financial assistance available under the American Rescue Plan Act constitutes an exceptional circumstance to qualify eligible consumers and enrollees for an SEP.  Access Health CT will open an exceptional circumstances SEP on this basis from May 1 through August 15, 2021.

Consumers not currently enrolled on Exchange may access the Exceptional Circumstances SEP
Any consumers not currently enrolled on Exchange may access the Exceptional Circumstances SEP and enroll in a plan commencing on May 1 through August 15, 2021 to gain access to new financial assistance through the American Rescue Plan.  Consumers may select any plan available on Exchange.

Enrollees may access the Exceptional Circumstances SEP
Any enrollee who wishes to change to a different plan will be permitted to change to any plan available on Exchange through the Exceptional Circumstances SEP commencing on May 1 through August 15, 2021 to maximize the new financial assistance available under the American Rescue Plan Act.