Insurers pushed back at the Biden administration’s efforts to extend the Affordable Care Act’s open enrollment period by another month and require them to post standardized plan options.
Several insurers and advocacy groups commented on the proposals outlined in the Centers for Medicare & Medicaid Services’ Notice of Benefit and Payment Parameters, which outlines ACA marketplace exchange regulations for the 2022 coverage year. Insurers worried that extending the open enrollment period could lead to adverse selection and raise premiums for consumers.
“Extending the open enrollment period could disincentivize consumers from enrolling in comprehensive coverage for a full 12 months and place consumers at risk for disruptions in care,” said America’s Health Insurance Plans (AHIP), the top health insurance lobbying group.
Over the past three open enrollment periods, the window for signups ran from Nov. 1 through Dec. 15. Now, CMS wants to extend that period for another month and end it on Jan. 15.
AHIP said that the change could cause gaps in coverage and confusion for consumers.
If a consumer enrolls after Jan. 1, for 2022 coverage, then their coverage won’t start until Feb. 1.
Alliance of Community Health Plans, which represents safety-net plans, offered a solution of pushing back the start date for open enrollment to Oct. 15 and the end date being Dec. 31, 2021. This will ensure that consumers won’t suffer any momentary gaps in care.
Another issue is that extending the open enrollment period could result in adverse selection as healthier members could defer enrollment until February and “unhealthier members would enroll in January which would increase costs and premiums,” commented Molina, a major ACA insurer.
The proposed rule, the comment period for which ended on Wednesday, would also create a monthly special enrollment period (SEP) that can be used by people who make up to 150% of the federal poverty level. The goal is to help people who may have been impacted financially by the pandemic and help to get coverage.
But ACA insurers balked at the creation of the SEP.
UnitedHealthcare commented that the period could lead to adverse selection and higher premiums “because eligible individuals would have nearly unrestricted opportunities to enroll in subsidized health coverage whenever they need to access benefits, while potentially dropping the coverage when they do not.”
The insurer, which has expanded its presence on the exchanges in recent years after scaling back in 2016, said that currently SEPs can help consumers who are impacted financially by the pandemic. If CMS does go forward with the SEPs then the agency must add guardrails.
“If the consumer elects to enroll, and subsequently terminates coverage, they should not be given another SEP during the coverage year,” UnitedHealthcare said.
Opposition to standardized plans
Another proposal that caused major opposition from most insurers was to resume standardized plan options and will propose new plan options for the 2023 payment notice. The proposal was in response to a federal court ruling in March that vacated a Trump-era rule that eliminated standardized benefit design.
UnitedHealthcare said that CMS should permit, rather than mandate, ACA insurers to offer standardized plan options.
“This approach gives [qualified health plan] issuers the latitude to continue pursuing innovative offerings that consumers want and increase overall choice for these consumers in the market” the insurer said in comments.
Major government insurer Centene commented that standardized plan options have “lower enrollment and are more expensive than non-standardized plans. Further, deferential display of standardized plan options may discourage consumers from fully exploring all available options to find a plan that best fits their individual healthcare and affordability needs.”
ACHP also slammed the inclusion of standardized options, noting that a “one size fits all approach does not work.”