Webinar Q&A: Get Ready for 2017 Open Enrollment & Health Insurance Plan Renewals
Webinar Q&A: Get Ready for 2017 Open Enrollment & Health Insurance Plan Renewals
The following questions and answers came from the October 20, 2016 ACE TA Center webinar, Get Ready for 2017 Open Enrollment & Health Insurance Plan Renewals.
- Who pays for the Advance Premium Tax Credits (APTCs)?
- Will my clients receive a renewal letter with information about Open Enrollment?
- When exactly does the Open Enrollment Period end in 2017?
- Do people applying have to know their ID and password from 2016 to access enrollment and redetermination information in 2017? If so, what is the process for helping them remember?
- If the client did not have any income and was living in a shelter, do they still need to file their taxes?
- How much is the national average Bronze plan premium? Is it the monthly or annual amount?
- What is ‘vigorously pursue’?
- Do you have pros or cons for working with CMS-certified brokers to assist with ACA enrollments?
- If a client loses coverage through their employer but has the option of COBRA, can the client still enroll in the Marketplace under special enrollment or does the client have to choose COBRA?
- Are there any changes in the ‘family glitch’ problem?
- What kinds of RWHAP assistance will be available for clients’ medical premiums payments?
- Where do my clients need to go to change or enroll in health insurance? Do they go to the website Healthcare.gov or to the local state-based marketplace?
- If you have someone who has Medicare Part A only, can they apply for health insurance through the Marketplace until eligible for Medicare Part B?
APTCs are payments that are made from the Marketplace to an individual’s insurer. If an individual receives the advance version, this payment is made every month. This amount is treated as enrollee income in the form of a tax credit. The enrollee can forego the advance version and simply get a premium tax credit when they file their taxes, but most RWHAP providers prefer that clients take the advance version. The tax credit will either lower their tax liability and decrease the amount of money they might owe after filing taxes, or add to their tax refund.
Yes, clients will receive two letters. One from the insurance company and one from the Marketplace. These letters detail the client’s current coverage and what will happen if they don’t take action in terms of automatic re-enrollment. They should receive these letters by Nov. 1st. Therefore, it’s very important to encourage clients to open their mail, especially any mail coming from the Marketplace or their insurance plan.
Here are the dates and deadlines related to 2017 Open Enrollment: https://www.healthcare.gov/quick-guide/dates-and-deadlines/
Yes, clients do need to keep track of that information. You can help them by making sure they have this information written down. Depending on your role (e.g., if you are a certified Navigator), you may not be permitted to keep this information for them, but you can help by making sure that they have set up an email address so that if they forget their password they’ll be able to reset it easily. Starting this year password reset links can be sent to any email address and is not limited to the email address that was used initially to log in.
This depends on whether or not the client was enrolled in Marketplace coverage and receiving advance premium tax credits.
If a client has no income or income below the IRS’s filing threshold and was enrolled in Marketplace coverage and received a premium tax credit: This client should still file paperwork with the IRS. The forms they would file would be IRS Form 1040:https://www.irs.gov/pub/irs-pdf/f1040.pdf (Individual Income Tax Return) and IRS Form 8962:https://www.irs.gov/pub/irs-pdf/f8962.pdf (Premium Tax Credits). Completing these forms for 2015 would reconcile the client’s tax credits so that they can continue to receive financial assistance in 2017. More information about how to help clients prepare for tax season including resources for filing can be found here: https://careacttarget.org/ace/financial-help-and-taxes
If the client was not enrolled in any coverage and has no income or income below the IRS filing threshold: This client would not need to file taxes. However, there may be situations in which the client decides to file taxes anyway. For example, some people will file if they have income below the IRS filing threshold but had taxes withheld from their W-2 and want to get a refund and/or other tax credits. In this case, if a client files and has been uninsured for one or more months of the year, the client could also apply for an exemption through the Marketplace due to homelessness, or could apply for an exemption on their tax return for having income below the filing threshold.
As of 2016, the national average Bronze plan premium is $2,676/year (https://www.irs.gov/pub/irs-drop/rp-16-43.pdf). For 2017, the average Bronze plan premium will increase slightly. Remember that Bronze plans are not necessarily the best value - it is important to look at each client’s health needs (including medications and provider visits), assistance available from the Marketplace (such as cost-sharing reductions for Silver-level plans), and from RWHAP, including ADAP that may be able to provide additional support to help clients pay premiums and/or out-of-pocket costs. These comparisons will help determine the best value for your clients.
Clients who do not have health coverage in 2017 will pay the higher of either: 1) 2.5% of their yearly household income, up to a maximum of the national average premium cost of a bronze plan, or 2) $695 (https://www.irs.gov/pub/irs-drop/rp-16-55.pdf). This is the annual amount a person would pay if they were uninsured for 12 months. If they were uninsured for less time than that, they’ll pay a pro-rated amount.
‘Vigorously pursue’ is explained in detail in HRSA Policy Clarification Notice (PCN) 13-05, entitled “Clarifications Regarding Use of Ryan White
HIV/AIDS Program Funds for Premium and Cost Sharing Assistance for Private Health Insurance” which can be found here: http://hab.hrsa.gov/program-grants-management/policy-notices-and-program-letters
Generally speaking, HRSA HAB’s expectation is that RWHAP recipients and subrecipients will make every reasonable effort to ensure all uninsured clients are assessed for all options in both public and private health care coverage. Recipients are expected to maintain policies regarding their required process for the pursuit of enrollment in health care coverage for all clients. These policies must include how the process will be documented by the recipient. The expectation is that recipients have established these policies to ensure they are vigorously pursuing client enrollment in health care options and can document this process in a way that HAB would be able to monitor when a site visit is conducted.
In November 2014, HAB led a webinar that discussed how "vigorously pursue" may be implemented and how protocols can be integrated into organizations. It also illustrates how one RWHAP recipient successfully created, deployed, and documented their process for vigorously pursuing health care coverage for the clients they serve. Here is a link to that webinar: http://services.choruscall.com/links/hrsa141113.html
The most important thing is for you, as a provider, to develop a strong rapport with whoever is enrolling your clients in health coverage, and make sure that the enrollment assister understands the specific concerns of your clients, as well as which plans (in your area) may be most appropriate for the needs of people living with HIV (PLWH). Also, make sure that any enrollment assister (navigator, certified application counselor, broker or agent) has received training from CMS. If you do not have partnerships in place, consider looking online at https://localhelp.healthcare.gov to find certified enrollment assisters in your area. To support your conversations with these providers, and help them understand the needs of PLWH, you may wish to begin the conversation by sharing ACE TA Center resources for enrollment assisters: https://careacttarget.org/library/resources-enrollment-assisters
Yes, if someone loses coverage through an employer, they will qualify for a Special Enrollment Period (SEP), even if they are eligible for COBRA health coverage through their previous employer.
COBRA can be expensive. If clients know that they will lose employer-based coverage and have the option for COBRA, then it would be important for clients to compare the costs of a Marketplace plan vs. COBRA coverage. If clients choose COBRA, they will be considered enrolled in “minimum essential coverage” (MEC) and therefore ineligible for Marketplace coverage with APTCs. However, if they want to enroll in Marketplace coverage with APTCs, they can do so through the loss of MEC SEP. If they will face a gap between when their employer coverage ends and their Marketplace coverage begins, they can enroll in COBRA to cover the gap, but should enroll in Marketplace coverage with APTCs first. Lastly, they should terminate COBRA before their Marketplace coverage begins (see Georgetown CHIR’s Navigator Resource Guide: http://navigatorguide.georgetown.edu/ FAQ 2.2.16).
The ‘family glitch’ is an implementation issue with the ACA. The way the law was written and interpreted, the test for determining whether or not employer-sponsored coverage for spouses and their dependents is affordable is based on the amount paid for individual coverage for the employee. If the amount an employee would pay for their premium is more than 9.69% of their income, they would be eligible for advance premium tax credits. However, if an employee enrolls into a family plan, the test for determining ‘affordability’ of the coverage is still based on the individual employee premium, despite the family plan premium likely costing more.
Unfortunately, this interpretation of the way the law was written has not changed.
This varies from state to state, and sometimes within states. There are many ADAPs that do provide substantial premium assistance. If you’re not sure whether or not your local ADAP does this, please consult the ADAP Coordinator Directory: https://www.nastad.org/sites/default/files/ADAP-member-directory-8816.pdf or ask your HRSA/HAB Project Officer if you have any questions. You can also find out if your local ADAP is evaluating plans and if they support specific ones that they feel are the best fit for ADAP eligible PLWH. RWHAP Part A may also provide premium assistance to clients in collaboration or in coordination with ADAP.
If someone is currently enrolled in Medicare, there is a rule that says private insurers are prohibited from selling them insurance that might be duplicative of their Medicare insurance benefits. However, if someone is eligible for or enrolled in premium Part A, they do have the option to decline premium Part A and enroll in Marketplace coverage with advance premium tax credits, instead. This is the one exception to that rule. For more information, see https://www.cms.gov/Medicare/Eligibility-and-Enrollment/Medicare-and-the-Marketplace/Downloads/Medicare-Marketplace_Master_FAQ_4-28-16_v2.pdf.