While open enrollment in the Marketplace ended March 31, there are still some important and new updates of which both businesses and individuals should be aware.
Special Enrollment Periods
With the Affordable Care Act (ACA), we all know that health insurance is now mandated. While millions have enrolled through the Marketplace during open enrollment, there are still many uninsured and some who will lose coverage throughout the year. Since open enrollment has ended, individuals must qualify for Special Enrollment Period in order to enroll for coverage. Some examples of qualifying events are moving to a new area, marriage, divorce, having a baby, adoption and losing group coverage. Voluntarily dropping coverage is not a qualifying event. If you have one of these events, you may have 60 days to enroll in coverage. Once this 60 day period is over, you must wait until the next open enrollment period, which is Nov. 15, 2014 through Feb. 15, 2015. American Indians, however, have an ongoing open enrollment period and can enroll at any time.
Grandmothered Plans
You have to love an industry that is so boring yet has so many interesting acronyms. Remember “grandfathered” plans? Those were the plans that were purchased before the health care reform law was signed and the president said, “If you like the plan you have, you can keep it.” Well, in November, the president opened the door (state by state) for insurers to allow people who have non-grandfathered plans to keep them for up to two years. In May, the Arizona Department of Insurance announced that they would allow Arizona insurers to allow “grandmothered” plans for up to two years. These are policies that were purchased between March 24, 2010 and December 31, 2013. If you have compared the cost of a “grandmothered” plan to an ACA plan, you probably noticed that the rates are typically much better on the “grandmothered” one. Let’s hope we can keep these as long as possible.
New COBRA Notices
For employers who are required to offer COBRA (those with 20 or more full-time employees during the preceding calendar year), there are new model notices that specifically address the availability of the Marketplace and Special Enrollment Periods. Under some circumstances, it will be very beneficial for an employee to enroll in the Marketplace (especially if that person qualifies for a subsidy). There will also be times when COBRA may be a more affordable option (especially for older employees). The Department of Labor has posted these model notices on their website:
www.dol.gov/ebsa/modelgeneralnotice.doc
www.dol.gov/ebsa/modelelectionnotice.doc
Pay or Play and DELAY!
President Obama gave mid-sized businesses a welcomed extra year to comply with the employer mandate. Employers with 50 to 99 full-time equivalents (not necessarily employees) now have until 2016 to comply with the employer mandate to offer minimum essential and affordable coverage to full-time employees. Those employers with 100+ full-time equivalent employees must offer coverage by Jan. 1, 2015 or face a sizable penalty.
Unsure how the Affordable Care Act affects you or your business? Give the team at Benefit Logic a call and we will be happy to sit down and review it with you. FBN
By Ed Gussio, Benefit Logic