As we head into the final few weeks of open enrollment, there’s likely to be a surge of applications both on an off the exchange. And that means an uptick in phone calls to carriers and brokers, ID cards and policies being mailed out, premium payments being processed… all of the things that go along with new health insurance policies, but coupled with a large number of people all trying to hit the same deadline.
Over the last five months (or at least the last three months since the exchange websites were mostly working well), Jay has spent hundreds of hours on hold with Connect for Health Colorado and the carriers selling individual health insurance in the state. He’s been working out all sorts of glitches and problems: difficulties processing early renewals back in 2013, delayed enrollment cards, buggy software, network confusions… it’s been a busy few months. Part of the reason for the various problems was simply growing pains; everyone is getting used to a new system and that always involves working out kinks. But volume has also caused its own share of problems. It’s like driving across Denver at 8am or 2pm… which would you rather do?
The rest of this year will be busy too. Many Colorado residents with individual health insurance opted to keep their old policies into 2014, and the coverage can remain in force until the policies reach their renewal date. For people who opted for early renewal, most existing policies will remain in force until December (which of course, coincides nicely with the general open enrollment for next year… I predict a very busy December for carriers and exchanges in states that allowed early renewal). But people also had the option to just keep their plan until its regularly scheduled renewal date in 2014, which means there will be policies ending throughout the year. When an existing individual policy ends, the insured qualifies for a special open enrollment period (loss of other minimum essential coverage is a qualifying event). So that means that throughout 2014, there will be people who are switching to new ACA-compliant health insurance policies.
And of course, there are also all of the normal qualifying events that have always caused people to shop for individual health insurance (they just weren’t called qualifying events in the past, because individual plans had year-round enrollment prior to 2014). Things like the birth of a baby, or moving into the state, or quitting one’s job in order to become self-employed… those will all trigger special open enrollment windows going forward, and they are naturally spread throughout the year.
But for people who don’t have a qualifying event, everyone’s policy renewals, rate increases, shopping and purchases will have to happen during one open enrollment window. For 2015, that window was originally scheduled to begin October 15, 2014 but was delayed to November 15. The end date was extended from January 15 to February 15 just last week, making the total open enrollment three months long.
Three months is certainly better than two, but it’s still a short period of time for carriers to process everyone’s policy changes and enrollments.
Don’t get me wrong – open enrollment is absolutely essential with guaranteed-issue health insurance. Group plans have long had open enrollment, and individual plans now very much resemble group plans, both in terms of coverage and price. Without open enrollment, the risk of adverse selection would be great. Even with the individual mandate and the shared responsibility penalty, there would be nothing to prevent people from selecting bronze plans to satisfy the mandate, and then switching to platinum plans at the first sign of a medical problem. In short, it wouldn’t work. We need open enrollment.
But do we need everyone to have the same open enrollment? Wouldn’t it be more efficient to try to spread policy changes and enrollments out across the whole year instead? That would allow staffing for carriers and exchanges to be more stable, and would create a better customer service environment for consumers who are trying to make changes to their plan or enroll in a new one.
Many aspects of ACA implementation have been moving targets, and while the law is here to stay, there are certain to be tweaks to it here and there as time goes on. Spreading open enrollment out across the whole year seems like a smart change that could be made. With a less bitterly divided political scene, it’s probably something that could be adjusted with a simple legislative fix. Although that seems highly unlikely in our current political climate.
But imagine how much less crazy December through February would be if we established a system that involved open enrollment being pegged to the primary policy-holder’s birthday (or something similar)? Special open enrollment triggers would still apply (those are easier to manage, since they’re naturally spread throughout the year), but general open enrollment would be spread across the year. The exchanges and carriers wouldn’t have to have extended hours (and two hour hold times) on Christmas Eve. That would be good for everyone involved.
— Jay Norris (@lukkyjay) April 29, 2014