Exchange Coverage Begins
Individual coverage purchased through the
federal and state-based Exchanges by December 24, 2013 went into effect January
1. Further, small employers generally may start offering
health insurance coverage to their employees through the SHOP Marketplace
(where enacted) at any time during the year.
As ACA-compliant policies are being
issued, more reforms covering pricing transparency, guaranteed issue,
elimination of annual and lifetime coverage limits, incorporation of Essential
Health Benefits for many plans and new wellness program incentives will
continue to take hold.
Individual Mandate Takes Effect
In addition to the new plans, the
Individual Mandate took effect January 1. While there are limited exceptions,
almost all Americans are required to maintain a minimum level of health
coverage or face a tax penalty.
January 10:
Insurance Payments Due for January 1
Coverage
While Americans had until December 24 to
enroll in a plan to receive coverage starting January 1, many health plans are
accepting first payments for these policies until January 10. America’s Health Insurance
Plans announced late last year that “Health plans across the country are
voluntarily giving individual market enrollees who select a plan by December 23
more time to pay their first month’s premium.”
If enrollees pay their first premiums by
January 10, they will be able to claim benefits retroactive to January 1. The
goal of this extension is to allow as many people to keep coverage following
the tumultuous year-end rush to enroll.
March 31:
Open Enrollment Period Ends
The initial Exchange “open enrollment”
period that began October 1, 2013 closes at the end of March. Federal
regulators wanted to allow as many people to enroll in health plans under the
new system as possible. In light of the early difficulties with federal and
state Exchange systems, the lengthy enrollment period affords consumers more
time to learn about the new system and shop for a plan that suits their needs.
After March 31, consumers will only be
able to enroll in new plans following qualifying events such as the birth of a
child or loss of employer-sponsored coverage. Americans who do not purchase
coverage by this date may be subject to a tax penalty under the ACA.
May 31:
Health Plan Rate Filings Due
Rate filings for 2015 plans must be
submitted by the end of May. The filing deadline was initially April 30, but
the deadline has been extended by a month to allow insurers more time to
calculate their expected costs. Because 2014 open enrollment does not end until
March 31, insurers have been given more time to analyze the enrollment data.
While last year’s premium rates were highly anticipated, 2015 rates will be
equally important to watch as insurers begin to factor real information about
Exchange enrollment trends into their premium calculations.
October 1:
All Renewal Coverage Must Be ACA Compliant
After receiving critical feedback last
fall about Americans losing coverage, President Obama made an administrative
policy change to uphold his promise that people could keep their insurance.
According to Centers for Medicare & Medicaid Services (CMS), plans renewed
after October 1, 2014 must be one of the plans originally "grandfathered
in" back in 2010, or they must meet ACA coverage requirements. It’s
possible a new wave of complaints about cancelled coverage will emerge next
fall, which was avoided for one year due to the President’s administrative
action.
November 4:
Mid-Term Elections
The mid-term elections will play a role in
the future of the ACA and the 2016 presidential election. In particular,
Republicans may have a chance to regain control of the U.S. Senate, which they
lost in 2006. This could have a significant impact on key elements of the ACA
in 2015.
November 15:
2015 Open Enrollment Begins
Because of the extension of the rate
filing deadline, open enrollment will begin a month later than expected.
Running from November 15, 2014-January 15, 2015, next year’s open enrollment
period will be significantly shorter than the inaugural year, but will be
lengthier than traditional enrollment periods. Once again, we will be analyzing
trends in Exchange and non-Exchange-based enrollments.
January 1, 2015:
Employer Mandate Begins
At the end of 2014, the Employer Mandate
will re-emerge as a hot potato as it will take effect for large employers on
January 1, 2015. As we have discussed in previous blogs, the Employer Mandate was delayed a
year. Starting next year,
it requires employers with more than 50 full-time equivalent employees to
provide full-time workers with affordable coverage, or face penalties/taxes of
either $2,000 or $3,000 per employee. The goal is to ensure as many American
workers are covered by health plans through their employers as possible.
It’s important to note that the federal
health care reform initiative discussed in this blog is referred to by several
different acronyms including ACA, PPACA and ObamaCare.
