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This is just them following the law. It's the way it's supposed to be. Not a glitch, not improper, not them being greedy.
45 cfr 155.420 (see, there I go, citing that exact same section again)
Specifically, and I quote (the relevant part):
"...in the case where a qualified individual loses minimum essential coverage, as described in paragraph (d)(1) of this section, the exchange must ensure coverage is effective the first day of the following month."
Hope this clears things up.
EDIT: Yes, even if you use the full 60 days of SEP, the plan is retro to the first of the month-clients owe 3 months premium on the first day in this scenario. I've had it happen. This is on or off exchange, any carrier, the same laws apply. Some carriers are blatantly not following this law, so exceptions are available if necessary.
RAY, a HUGE THANK-YOU for finding and sharing the actual ACA wording that describes when ON and OFF Exchange SEP health policies must be effective. Your R.W.I.Q. is off the charts!
Most appreciative,
-AC