Special Enrollment Periods

Three weeks ago I reported that there were growing calls from many quarters for CMS Administrator Seema Verma and HHS Secretary Alex Azar to open up a federal Special Enrollment Period at HealthCare.Gov tied specifically to the COVID-19 pandemic.

Over the next week or so, more and more of the 13 state-based ACA exchanges announced just such a COVID-19 SEP; eventually 12 out of 13 state-based exchanges did so (Idaho is the odd man out), and eventually even the health insurance industry (which is normally opposed to allowing exceptions to the official Open Enrollment Period) were onboard with a COVID SEP. Two weeks ago I was 95% certain that HC.gov would be announcing one at any moment.

And then...nothing. Nothing last week. Nothing yesterday. Nothing as of this writing.

For a couple of weeks now, I've been posting constant updates as one state-based ACA exchange after another has announced a COVID-19-specific Special Enrollment Period in light of the ongoing pandemic crisis. Until now, though, there's been two ACA exchanges which haven't made such an announcement. One is the Big One, HealthCare.Gov, which hosts a whopping 38 states and which is facing increasing pressure to do so.

The other...is Idaho. Specifically, Your Health Idaho, the state's ACA exchange.

This just in via MNsure...

MNsure Announces Special Enrollment Period for Uninsured Minnesotans in Response to Growing COVID-19 Concerns

ST. PAUL, Minn.—Today MNsure announced a 30-day special enrollment period (SEP) for qualified individuals who are currently without insurance, in response to the potential growth of coronavirus (COVID-19) cases. This SEP that begins Monday, March 23, and runs through April 21, will allow uninsured individuals 30 days to enroll in health insurance coverage through MNsure.org.

“As more cases of COVID-19 are diagnosed throughout the state, we want to make sure every Minnesotan has the security of health insurance to ensure they can get the care they need if they contract this serious illness,” said MNsure CEO Nate Clark. “Uninsured Minnesotans can come to MNsure.org to sign up for coverage.”

Governor Tim Walz recently declared a peacetime emergency in response to the pandemic and stressed the importance of all Minnesotans to take care to avoid the spread of COVID-19.

California Responds to COVID-19 Emergency by Providing Path to Coverage for Millions of Californians

  • Covered California Expands Special Enrollment and Medi-Cal Seeks Waivers to Encourage Coverage
  • Effective immediately, anyone uninsured and eligible to enroll in health care coverage through Covered California can sign up through the end of June.
  • The Department of Health Care Services announces new steps to help those eligible for Medi-Cal sign up easily and get immediate coverage.
  • The moves come amid widespread disruption in the lives and livelihoods of Californians as public health officials seek to reduce the spread of COVID-19.
  • All medically necessary screening and testing for COVID-19 are free of charge, and all health plans available through Medi-Cal and Covered California offer telehealth options.
  • These actions build on increased state subsidies and the implementation of a state penalty, both of which took effect in January 2020

No one has been shouting from the rooftops louder than I have for HHS Secretary Alex Azar or CMS Administrator Seema Verma to join nearly all of the state-based ACA exchanges in announcing an official Special Enrollment Period (SEP) in light of the ongoing Coronavirus pandemic, and I'm still urging them to do so as soon as possible. The federal ACA exchange, HealthCare.Gov, hosts ACA enrollment for 38 states representing around 75% of the national population, so this is a pretty big deal.

Having said that, it's important to keep in mind that even without a COVID-19-specific SEP, many people already qualify to enroll in ACA-compliant healthcare coverage anyway, whether they're currently uninsured or because they're about to be...or because their personal circumstances are about to change. And none of these have anything to do with the COVID-19 crisis, although it's certainly going to cause a whole lot more people to qualify for two of those changes:

Special Enrollment Period (SEP)

This Just In via Vermont Health Connect...

The State of Vermont has made temporary changes to assure that Vermonters have access to health insurance. Please visit https://t.co/dXz4Cd2yQm for more information

— VT Health Connect (@VTHealthConnect) March 20, 2020

OK...that's about as vague and understated as you can get. Clicking the link doesn't make it any more obvious:

Stay informed and protect your health.

via the Colorado Dept. of Regulatory Agencies Insurance Division, it looks like Connect for Health Colorado is about to go ahead and establish their own COVID-19 Special Enrollment Period after all (this is from an internal draft document...the dates could still change, and it's not 100% guaranteed that they'll go ahead with it yet):

DEPARTMENT OF REGULATORY AGENCIES Division of Insurance 3 CCR 702-4 LIFE, ACCIDENT AND HEALTH

DRAFT Emergency Regulation 20-E-02

CONCERNING ESTABLISHING A SPECIAL ENROLLMENT PERIOD FOR ENROLLMENT IN AN INDIVIDUAL HEALTH BENEFIT PLAN RELATED TO COVID-19

...This emergency regulation is promulgated and adopted by the Commissioner of Insurance under the authority of §§ 10-1-108(7)(a), (7)(b)(III), 10-1-109(1), 10-16-105(2)(b), 10-16-105.7(3)(a)(II)(G), 10-16-105.7(3)(b)(II)(F),10-16-108.5(8), and 10-16-109, C.R.S.

Section 2 Scope and Purpose

via Access Health CT:

Access Health CT Announces A New Special Enrollment Period For Uninsured Connecticut Residents

AS COVID-19 THREATENS PUBLIC HEALTH, ACCESS HEALTH CT ANNOUNCES A NEW SPECIAL ENROLLMENT PERIOD FOR UNINSURED CONNECTICUT RESIDENTS

New Special Enrollment Period starts Thursday, March 19 and ends Thursday, April 2

One week ago, in light of the growing COVID-19 crisis, I noted that California, the District of Columbia and Maryland were each offering Special Enrollment Periods which had nothing whatsoever to do with the pandemic.

California's SEP is for uninsured residents who didn't know that the state had reinstated the individual mandate penalty and expanded financial subsidies to those earning 400-600% of the Federal Poverty Line; DC is offering one for those who didn't know they had also reinstated the mandate penalty; and Maryland passed a clever law last year which lets residents check a box when they file their state taxes if they're uninsured which tells the state to contact them to help them enroll.

I concluded that:

...as far as I know, there's nothing preventing other state-based exchanges from establishing Special Enrollment Periods for the coronavirus crisis if they want to.

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