Virginia jumps on the #TaxTimeSEP bandwagon as well; "Facilitated Enrollment Program" passed last year, being phased in over 2 yr period


As I noted in a bunch of posts yesterday, several states have launched "Tax Time Special Enrollment Periods" (Maryland launched theirs a couple years ago; Colorado, Massachusetts & Pennsylvania are bringing their programs online right now). New Mexico is also moving their own version through the legislative process.

Well, it turns out (thanks to Louise Norris for the heads up) that Virginia also passed their own version of this bill last year...although in their case it's being phased in over a two year time period:

HB 1884 Income tax, state; voluntary inclusion of personal & contact information on appropriate forms.

Facilitated enrollment program. Directs the Department of Taxation to include space on the appropriate individual income tax forms for voluntary inclusion of personal and contact information. Such information may be shared with the Department of Medical Assistance Services, the Department of Social Services, or the Virginia Health Benefit Exchange, as applicable, for use in determining eligibility for certain programs.

Beginning with tax year 2022, the Department of Taxation shall also include a checkoff box for taxpayers to indicate their consent to the sharing of tax information with the Department of Medical Assistance Services and the Department of Social Services.

Beginning with tax year 2023, there shall also be included a checkoff box for taxpayers to indicate their consent to the sharing of tax information with the Virginia Health Benefit Exchange. The bill contains provisions allowing disclosure of such information in accordance with the act. The bill also directs the Virginia Health Benefit Exchange to, in consultation with other government agencies and stakeholders, identify systems, policies, and practices to facilitate eligibility determinations and enrollment.

Again, the idea behind Tax Time SEPs is that a lot of people miss the Open Enrollment Period deadline without realizing that they would've been eligible to enroll in free (or nearly-free) ACA coverage or Medicaid/CHIP if they had done so. You can actually enroll in Medicaid/CHIP year round regardless, but again, a lot of people have no idea that they're eligible.

One of the main reasons for having a time limited enrollment window for ACA policies is to avoid adverse selection--that is, people who game the system by "going bare" (without any healthcare coverage at all) for months on end, knowing that they can enroll any time they want the moment they're diagnosed with some expensive medical ailment or get some serious physical injury. That would be the equivalent of letting people sign up for auto insurance after they crash their car, or buy homeowners insurance after their hous catches on fire.

HOWEVER, the rules are different in cases where the enrollee doesn't have to pay anything in premiums regardless. There's no point in deliberately "going bare" to save money if getting enrolled in an ACA plan wouldn't cost you anything on a monthly basis anyway. The same holds true (to a lesser extent) for low-cost's one thing to gamble like this if the alternative is paying, say, $1,000/month in premiums...but what if you'd only have to pay $10/month?

With that in mind, Tax Time SEPs give uninsured residents a second chance to #GetCovered when they file their state tax returns. It really amounts to simply checking a box giving the state permission to check and see whether they're eligible for free coverage (Medicaid/CHIP; ACA plans in some cases) or very low-cost coverage (highly-subsidized ACA plans).

If they're not eligible for any of the above, no harm no foul; they aren't any worse off than they already were. If they are eligible, however, several thousand people who would otherwise be uninsured now find themselves with comprehensive healthcare coverage at no cost to them (and nominal additional cost to the state).

In Virginia's case, they have to phase the program in over 2 years because they haven't yet launched their own state-based ACA exchange (SBE). That means they can only implement the Medicaid/CHIP provision for now, followed by the subsidized ACA plans the following year. Virginia's SBE is supposed to go live this November.

To be honest, the wording of the description is a bit confusing--the state of Virginia has already added the checkbox/line to the 2021 state tax form...

_X_ "I/we are uninsured and authorize the sharing of certain information from Form 760 and Schedule ADJ (as described in the instructions) with the Department of Medical Assistance Services (DMAS) for purposes of identifying persons who would like to newly enroll in medical assistance."

...but the wording of the law makes it sound like they don't actually do anything with it until starting next year, which seems odd, but whatever.