Open enrollment – including extensions – in the individual health insurance market officially ended more than two months ago, on April 15 in most states, including Colorado. Connect for Health Colorado gave enrollees until the end of May to enroll if they were still waiting for a Medicaid denial as of the end of March, but in most cases that documentation was processed much faster than that (everyone applying through the exchange in Colorado has to first go through the Medicaid eligibility process; private health insurance enrollment takes place after an applicant is found to be ineligible for Medicaid).
As expected, application volume slowed down considerably after the middle of April. But also as expected, it has continued to grow, slowly but steadily. About 11,000 enrollments were submitted in April (all people who either had a qualifying event or who were allowed to enroll during the extension that was offered until April 15). And another 5,000 were submitted in May. Even though there were still some open enrollment straggler applications being processed during May, my guess is that most of those 5,000 enrollments were triggered by a qualifying event. Our own experience with our clients was that for everyone who was still waiting for a Medicaid denial letter as of the end of March, enrollment had been completed by the end of April. There was some backlog with the Medicaid denial process, but at least for our clients, it didn’t extend into May.
Total health insurance enrollment numbers through Connect for Health Colorado reached nearly 135,000 by the end of May. We still have five months until open enrollment begins for 2015 (on November 15, 2014) and I predict that health insurance enrollment will continue at about 4,000 to 5,000 people per month between now and then. I think the exchange will go into the 2015 open enrollment period with an enrollment of 150,000+ people (there will be some attrition, at the individual market has always been relatively volatile). And unlike last year, when the first couple months of open enrollment were generally a mess, the 2015 open enrollment period will be a much smoother experience, right from day one.
I’ve updated our qualifying event post to reflect some new federal regulations that were released at the end of May. If you feel like reading the nitty gritty details, here’s the Federal Register with the updated special open enrollment info (section 155.420, and the pertinent information starts on page 30296).
Main Qualifying Event Changes for Health Insurance Enrollment
- People who are losing individual coverage have 60 days in advance of the termination date during which they can select a new plan and ensure continuous coverage. This was always the case for people losing group coverage, but not for individual plans. Connect for Health Colorado had already been granting advance open enrollment for people who were going to be losing non-group coverage, but it’s now a federal regulation too.
- The effective date for a newborn or newly adopted/fostered child can still be the date of birth/adoption/foster placement, but the parents now have the option to select the first of the following month instead, if they wish. Previously, the coverage was automatically back-dated to the triggering event date.
- Women who are losing eligibility for Medicaid pregnancy-related coverage still qualify for a special open enrollment period, even though the coverage that is terminating is not considered minimum essential coverage.
- People with individual health insurance that has a plan year that does not align with the calendar year will have a special open enrollment period even if their existing individual plan is eligible for renewal. Loss of other coverage has been a qualifying event from the start, meaning that an individual plan that was terminating outside of open enrollment would allow the member a chance to select a new ACA-compliant plan on or off-exchange during a special open enrollment period. Some carriers had already been treating renewal (rather than just termination of coverage) as a qualifying event, but now it has officially joined the list of ACA qualifying events for the individual market. People who opted to keep their non-grandfathered, pre-2014 plans into this year were initially told that those plans would terminate on their 2014 renewal date and need to be replaced with an ACA-compliant plan. But in March, the Obama Administration announced that non-grandfathered, pre-2014 plans could be extended up to two more years (in addition to the one-year extension that was granted last fall). It was left up to the states to decide if they would allow this (Colorado did), and in states that agreed to the extension, it was left up to each carrier to determine whether or not that option would be offered. So while some states no longer have any pre-2014 plans (other than grandfathered plans), there are plenty of states (including Colorado) where pre-2014 plans will continue to be in existence next year and possibly the year after. But people who have those plans are not locked into them at renewal. They can opt to keep the plan and accept the new renewal rate, or they can shop for a new ACA-compliant plan, on or off-exchange.
All in all, the list of qualifying events is pretty comprehensive. Health insurance enrollment will continue to climb throughout the “off-season” here in Colorado and across the country. If you’re curious about enrollment nationally, ACA Signups is an excellent resource.