This is a continuation of the Special Enrollment Period verification conversation from earlier in the week. I am of the opinion that the new CMS requirement for eligibility verification for the four major qualifying events is a reasonable accomodation to insurer’s needs to promote a more stable market and for people with legitimate qualifying events, not a significant barrier. Someone I greatly respect disagrees.
Data show fewer than 15% of SEP eligible have used SEP; roadblocks shouldn’t be priority. https://t.co/DRUq5ZA6zM https://t.co/av9cR2hhiq
— Claire McAndrew (@claire_mcandrew) February 25, 2016
The five major QE’s that make up 75% of the SEP triggers that now need verification are:
- Loss of minimum essential coverage
- Permanent move
- Birth
- Adoption, placement for adoption, placement for foster care or child support or other court order
- Marriage.
From my perspective, the triggering event produces official paperwork in four of the five scenarios and that paperwork arrives very quickly. It is not a case of an individual needing to find an original birth certificate from halfway across the country. Is my middle class privilege overwhelming reality here? I don’t think so, but I need a reality check
The loss of minimum coverage triggers a COBRA eligibility letter if the loss of coverage is because of a job loss that had ESI. If an individual makes too much for Medicaid or otherwise loses Medicaid/CHIP, a termination letter with appeals rights is sent. If the loss is due to the non-payment of premium, termination letters are sent. This is recent paperwork.
Birth of a new baby produces lots of poop and a birth certificate.
Marriage produces a marriage license. Divorce produces a divorce decree. Both of those documents are freshly produced after 1/1/16.
Adoption, foster care, adoption placement, and child support produces reams of legal documentation and orders. And again, this is fresh documentation after 1/1/16.
The hardest one to prove for some people is permanent move. Middle class individuals can easily produce a signed lease or a mortgage or several bills at a distinct address. However, people who are far less connected to the system may be using informal housing arrangements without leases or documentation, and they may only have a few bills and no bank account. Those bills could be paid online and thus it would not matter if they all still went to a parent’s address 2 states away as they always were thrown away. This is a challenge in my mind, but that is the only QE that is not guaranteed to produce recent verification documentation.
Does this make sense?