Opportunities to Purchase a Health Insurance Plan after Open Enrollment

The grid below comes from BCBS of IL (but applies to ALL states) and articulates what is considered a special enrollment, who is impacted, the timeline, and when a new policy would be effective. If you are unsure, ALWAYS talk to me as this chart doesn’t cover all circumstances.

NOTE: You can always purchase a Short Term Medical policy outside of open enrollment and special enrollment periods. Contact me for more information.

NOTE2: You can sign up for Medicaid at any time if you qualify (there are no enrollment periods).

Qualifying events can initiate a Special Enrollment Period (SEP) under the Affordable Care Act (ACA), and may allow your clients a window of time to select a new benefit policy or make a change to an existing policy. Here are events, enrollment dates and effective dates that may trigger an SEP. Categories that warrant special enrollment periods may be added in the future if other appropriate circumstances, as determined by CMS, become known.

Qualifying Event	Enrollment Period	Effective Date
Applicable to both Marketplace and non-Marketplace (on- and off-Exchange) Policies
Gaining/losing a dependent through birth/adoption/foster care/placement for adoption	60 days	Date of event
Gaining a dependent through marriage		First day of the following month after the event
Loss of Minimum Essential Health Coverage (MEC)*
Loss of eligible coverage from: Legal separation/divorce Cessation of dependent status (aging out) Death Termination or reduction of working hours with employer
Loss of coverage through an HMO due to relocation (applicable to both group and individual markets)
Incurs claim that meets or exceeds lifetime limits on all benefits
COBRA coverage ends
Employer ceases contributions either to subscriber or dependents	60 days	First day of the following month after the event
Permanent move		If the selection of the plan happens between first and fifteenth – the effective date is the first of the next month. If the selection of the plan happens after the fifteenth – the effective date is the first of the second following month.
Newly eligible/ineligible for advanced payments of tax credits or change in eligibility from cost-sharing reductions
Qualified Health Plan (QHP) substantially violates a material provision of its contract
Enrollment in QHP is made in error
Applicable to non-Marketplace (off-Exchange) Policies Only
Enrollment in non-calendar year policy ends	30 days	Date of event
Applicable to Marketplace (on-Exchange) Policies Only
Native American status	60 days	Eligible to enroll or change QHP policies on monthly basis
Attaining citizenship		Date of event
Demonstration of exceptional circumstances, as determined by the Exchange		Date of event

*Does not include loss of MEC due to failure to make premium payment and situations for allowable rescissions.

Individual Health Insurance Exchange (Marketplace) Subscribers and the 90 Day Grace Period to Pay Your Premium

Below is how BCBS of IL will handle claims for those people who have gotten a health insurance plan on the Exchange (Marketplace) AND receive a subsidy (Advance Premium Tax Credit).

It is my understanding that most other insurance carriers will be following a similar methodology, hence why I am posting this.

This is NOT for Small Group SHOP plans.

Blue Cross and Blue Shield of Illinois Providers Notified of ACA Grace Period Provision Providers will be receiving information in the Blue Cross and Blue Shield of Illinois (BCBSIL) provider newsletter about the Affordable Care Act (ACA) provision that allows Health Insurance Marketplace enrollees who receive the advance premium tax credit (APTC), a three-month grace period to pay their premium — provided they have already paid at least one month’s premium in full. It is important to note that not all members who purchase coverage on the Marketplace will receive the tax credit. During the three-month grace period, members are eligible for covered services under their plan.

The provision requires all payers to complete claims (for covered services rendered) in the first month of the grace period. For covered services rendered during months two and three, payers must either pay or hold claims for processing once the payments have been received. Notification of Eligibility Providers will be informed through eligibility and benefits verification when a member has entered into a grace period during months two and three of the grace period. All preauthorization letters will encourage providers to confirm whether the member is in a grace period prior to providing services. Claims Processing Payment for all allowable services provided during the first month of the grace period will be the responsibility of BCBSIL, subject to member cost sharing. During the second and third months of the grace period, BCBSIL will pend the claims the member incurs during this period. If the member pays all outstanding premium payment(s) in full, claims incurred during this period will process according to the member’s benefits. If the member has not paid premiums in full by the end of the grace period, BCBSIL will terminate the member’s policy retroactive to the first day of month two of the grace period. BCBSIL will deny any claims pended in months two and three of the grace period. Pharmacy Claims A member’s pharmacy claims will be denied during months two and three. If the member retroactively pays the premium in full, they may submit claims for prescriptions dispensed during this time to BCBSIL. If a member elects to receive a 90-day supply of a prescription during month one of the grace period, the member will receive the full 90-day prescription and BCBSIL will pay this claim. Member Responsibility for Payment We are encouraging providers to notify their patients that they will be responsible for payment of any outstanding claims for the full cost of provided services, if their health care coverage terminates at the end of the grace period.