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Important Guidance on Exchange Marketplace Enrollment Now That Open Enrollment Has Technically Closed

After 11:59 p.m. on March 31, 2014, open enrollment for the majority of health insurance exchanges across the country closed. However, if you have a client who attempted to enroll in federal exchange coverage prior to March 31, 2014, but the client was not able to complete their enrollment successfully, chances are they can still enroll through a special enrollment period and obtain coverage for this year if they act quickly. As of April 1, 2014, every state-based exchange has also announced some type of enrollment relief for people who had trouble making the deadline, but eligibility and access to that relief varies significantly by state-based exchange. So that you have all the tools you need to help your marketplace-based clients moving forward, below is detailed information about the post-open enrollment status for the federal exchange and each state-based exchange.

Additionally, to help agents and brokers and other assisters determine if their clients will qualify and guide them through the process, the Centers for and Services (CMS) released these tips for assisters and more detailed guidance for health insurance issuers:

Overview of the New Change in Circumstances Functionality Assisting consumers who are trying to enroll by March 31? We can help. Helping Consumers with Complex Cases Enroll in Special Enrollment Periods in the Health Insurance Marketplace

Guidance for Federally Facilitated and Partnership Exchanges:

If you have a client who attempted to purchase marketplace-based health insurance coverage in a federally facilitated or partnership exchange but couldn’t complete the transaction due to a marketplace complication or extreme circumstance, just follow the steps below to help them get enrolled. The federal exchange has not specified for how long they will keep this process open, so we encourage our members to start this process with their clients quickly.

If a client has already established a marketplace online account, they can click here and attempt to finish the process.

Alternatively, if a client has not already established a marketplace online account, they can:

1. Call the call center and request the special enrollment period due to http://www.magnetmail.net/....cfm?recipient_id=1012450209&message_id=3932519&user_id=NAHU_2&group_id=852094&jobid=17801087[4/5/2014 2:26:12 PM] ::

a marketplace complication. 2. The call center will ask the consumer a variety of questions to determine if the consumer is eligible. The consumer will then be approved or denied for the special enrollment period. Either way, the marketplace will inform the consumer of their status. 3. Once approved for the special enrollment period, the call center will activate the special enrollment period and the consumer can go on to complete enrollment. Once enrolled the consumer should receive plan information from their issuer.

If the special enrollment period is denied, the consumer may issue an appeal. For more information on filing an appeal, click here.

CMS will also process paper applications received by April 7 to capture those consumers who were “in line” with paper applications or whose applications were pending submission or review of supporting documentation on March 31. Consumers who submitted a paper application that was received by April 7 will have until April 30 to select a plan.

For your reference, items CMS will consider a marketplace complication are listed below. The consumer will have to attest to the applicability of one of these situations.

Exceptional circumstances An unexpected hospitalization or temporary cognitive disability A natural disaster, such as an earthquake, massive flooding or hurricane A planned marketplace system outage, such as a Social Security Administration system outage Misinformation or misrepresentation Misconduct by a non-marketplace enrollment assister (like an insurance company, navigator, certified application counselor, agent or broker) that resulted in you: Not getting enrolled in a plan Being enrolled in the wrong plan Not getting the or cost-sharing reduction you were eligible for Enrollment error Your application may have been rejected by the insurance company’s system because of errors in reading the data or some of the data was missing or inaccurate. System errors related to immigration status An error in the processing of applications or system caused you to get an incorrect immigration eligibility result when you tried to apply for coverage. Display errors on HealthCare.gov Medicaid/marketplace transfers If you applied for Medicaid through your state, or were sent to Medicaid from the marketplace, but you weren’t eligible for Medicaid

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Your state transferred your information to the marketplace but you didn’t get an answer about your eligibility and/or didn’t get enrolled before March 31. Error messages Unresolved casework You’re working with a caseworker on an enrollment issue that didn’t get resolved before March 31. Victims of domestic abuse Other system errors Other system errors that kept you from enrolling, as determined by CMS

Guidance for State-Based Exchanges:

California To qualify for an extension, Covered CA is requiring consumers to have started the application process before midnight on March 31. Per coveredca.com, “If you had trouble applying due to website issues, please visit a certified agent or broker to complete your enrollment by April 15. For those who started but have not completed an application, please log on to your account and complete your application by April 15.”

Colorado Connect for Health has granted an extension, but hasn’t set a hard-and-fast date by which people need to complete their applications. If someone “demonstrates” they’ve tried to apply, they’ll get more time.

Connecticut initially touted the success of their website and said they were sticking to the March 31 deadline. Apparently Governor Dannel Malloy didn’t like being the lone state holdout though because late in the day on April 1, 2014, he tweeted, “@AccessHealthCT will continue working w/ residents who began the enrollment process but have not yet completed it.”

Hawaii Hawai’i Health Connector is directing visitors to fill out an online form stating that they’ve tried to enroll but were unable to finish. The website has not announced a cut-off date for those who qualify.

Idaho To qualify for an extension, Your Health is requiring consumers to have started the application process before midnight EST on March 31. Per ’s call center, the extension for those who started the process is not definitive yet. They are currently expecting the extension period to come to a close either on April 7 or April 14.

Kentucky To qualify for an extension, is requiring consumers to have started the application process before midnight on March 31. Per the Kynect helpline, these consumers will have until April 15 to complete the enrollment process.

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Maryland A two-week extension has been granted, but people seeking the extension must have called the hotline ( 1-800-396-1961 ) before midnight on March 31 to verify that they attempted to enroll by the deadline and requested the extension.

Massachusetts extended the deadline to enroll in health coverage, giving two additional weeks to residents who have been stymied by the state’s faulty health insurance website. The extension from March 31 to April 15 applies to those who do not qualify for subsidized coverage and who assert that they experienced problems with the website.

Minnesota MNsure is directing visitors to fill out an online form stating that they’ve tried to enroll but were unable to finish. Consumers are asked to indicate how they’ve already tried to apply, such as visiting a navigator or emailing the exchange, and the form must have been submitted by midnight on March 31.

Nevada Due to the problems from the exchange website since it went live in October, a special enrollment period has been extended. It starts April 1 through the end of May for those who attempted to enroll and were unable to finish because of the glitches. Consumers will need to be recognized in the system through an ID number. Health Link says to avoid a pro-rated penalty, a consumer will need to pay by April 15.

New Mexico In , the open enrollment deadline has not been extended. However, customers who were unable to successfully enroll in a plan by March 31 may qualify for enrollment on a case-by-case basis. Customers may request an extension by getting their name on NMHIX’s waiting list. NMHIX will contact customers on the waiting list who were unable to complete their applications. Affected customers may also call 1-855- 99-NMHIX .

New York will allow residents more time to apply for health insurance via the state's online marketplace. The delay provides two additional weeks for enrollment, but is supposed to apply only to people who have tried to apply for health insurance, but ran into the now-notorious technical difficulties.

Oregon Oregonians who haven't been able to enroll in health insurance through the troubled Cover website will receive a one-month deadline extension to April 30. Those who apply for coverage for a private plan through by April 30 and enroll after the initial deadline of March 31 won't be subject to a potential federal penalty.

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Rhode Island Rhode Islanders who began the enrollment process but were unable to complete their enrollment by 11:59 p.m. on March 31 due to a system issue may qualify for a special enrollment provision that lets them complete their enrollment after March 31 and should contact the state exchange for more information.

Vermont State officials said that Vermonters who started the enrollment process but ran into difficulties and failed to complete it by the close of business Monday would still be able to finish signing up.

“If Vermonters have had trouble signing up during open enrollment, our Health Connect team will make sure they have the health plan they need and it starts on the correct date,” stated Emily Yahr, public information officer for . “We ask that Vermonters call us toll-free at 855-899-9600 to talk to one of our customer service representatives about any issues they may have experienced.”

Washington is sticking closely to the Monday deadline, allowing only case- by-case review for people who hit technical glitches before midnight on March 31. Extension requests from consumers will be individually reviewed to confirm they actually were delayed by a technical error.

Washington, DC The District of Columbia's exchange is keeping enrollment open until April 15 for those who say they had trouble signing up earlier.

Qualifying Life Events:

In all state-based, federal and partnership exchanges, individuals may also enroll outside of the open enrollment window if they have a qualifying life event. The consumer and the agent should contact each specific exchange directly for their qualifying life event procedures. For your reference, qualifying life events include:

Marriage Having a baby Adopting a child or placing a child for adoption or foster care Moving outside your insurer’s coverage area Losing other health coverage—due to losing job-based coverage, divorce, the end of an individual policy plan year in 2014, COBRA expiration, aging off a parent’s plan, losing eligibility for Medicaid or CHIP and similar circumstances. Important: Voluntarily ending coverage doesn’t qualify you for a special enrollment period. Neither does losing coverage that doesn’t qualify as minimum essential coverage. Gaining citizenship Leaving incarceration Gaining status as member of an Indian tribe. Members of federally recognized Indian tribes can sign up for or change plans once per http://www.magnetmail.net/....cfm?recipient_id=1012450209&message_id=3932519&user_id=NAHU_2&group_id=852094&jobid=17801087[4/5/2014 2:26:12 PM] ::

month throughout the year. For people already enrolled in marketplace coverage: Having a change in income or household status that affects eligibility for premium tax credits or cost-sharing reductions

National Association of Health Underwriters 1212 New York Ave NW, Ste 1100, Washington, DC 20005 Ph. 202.552.5060 Fax 202.747.6820 www.nahu.org

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