Can Marketplace Health Insurance Terminate for Not Sending In Documents?

We need to all bombard this email about this very bad situation:

This person says he is the Broker's Advocate at The White House:

Rhett A. Buttle (OS/IEA)
Director, Private Sector Engagement
Office of The Secretary
U.S. Department of Health & Human Services
Ofc. #: (202) 690-6060
email: [email protected]

These emails are read. I did get a call back about pay issues. If enough of us
send in messages daily we will be heard.

Something needs to be done about yet another poor system. This is just too ridiculous for words.

Thank you for posting this information. I sent an email today and they responded very quickly and said they are working to find the best resolution. They asked to give them a little time while they looked into it and would advise with a resolution.

The following was my email to them with what I learned today:

"It is our understanding the Marketplace recently received 2014 Income Tax Information from the IRS.

When reviewing our book of business with various carriers, we have noticed quite a number of marketplace policies terming 04/30/15 (premium with APTC) with a new policy becoming effective 05/01/15 (full premium with no APTC). In addition, our clients are now receiving letters advising them they did not send in documents to prove their income thus their tax credit is being taken away from them.

Not only have these clients sent in the documentation, they have each mailed the documents several times and have also uploaded the documents to their marketplace account well before the requested due date of the documents. However, when they reach out to the marketplace, the marketplace is never able to confirm whether or not they have received the requested documents let alone whether or not the documents were sufficient. Each time the marketplace advises, "if we need anything else we will send you a letter advising of same" or "if the documents are not sufficient, you will receive a letter explaining specifically what is needed."

A marketplace representative advised this morning healthcare.gov is not able to differentiate policies, effective dates, etc. It was initially set up to flag policies when new data came in from the IRS to show inconsistent information for previous year's policies. The following is what the marketplace advised was supposed to have occurred recently:

Policies with an original 2014 effective date-
when these were submitted in 2014, the applicants provided income information as far as their 2014 income and projected 2015. The marketplace just received 2014 data from the IRS. The system should have looked at only people who had policies effective in 2014 to search for inconsistent information; however, rather than dividing people into policy year and application date of 2014 or 2015, the system is looking at everyone who has a policy through the marketplace.

Even though the marketplace used 2014 data to assist in determining whether or not someone would qualify for a Tax Credit for tax year 2015, the marketplace has taken 2014 data and readjusted or removed completely the monthly Tax Credit for these individuals even though most of these individuals have sent in to the marketplace documentation illustrating their change in MAGI from 2014 to 2015.

The marketplace advised this morning even though these individuals may have submitted the requested documents, the system is not recognizing this and just simply utilizing their 2014 IRS data. The marketplace advised they are aware of this issue.

Their recommended resolution for now:
Have each person reapply through the marketplace due to a change of income which would make their new policy effective date 06/01/15. (The policyholder would be responsible for the entire premium for the month of May.) The marketplace advised it was okay that they would owe the entire premium for May as they would "get that money back" when they file their taxes for 2015 so no need to worry.

Issue 1 : Policyholder owing back premiums for the Tax Credit applied to their policy for months January - April:

Currently the carriers have not generated updated invoices for any of these policyholders for May. Once the invoices are generated, the new invoices should request the full premium for May as well as the amount of APTC paid on their behalf for the months of January, February, March and April. (Meaning if someone was receiving a Tax Credit of $500.00 per month, the updated May invoice would reflect their entire May premium along with a balance of $2,000.00 for APTC). These types of monies may be difficult for some people to come up with to keep their policy active. If these individuals do not pay the carriers for these tax credit amounts that were advanced to them and now being invoiced to them, their policy will terminate for non payment.

When I brought this to the attention of the marketplace and asked about this, their response was, "OOOHHHHHH." One marketplace rep said the carrier would not request the monies back especially "if the individual was entitled to the tax credit." So I asked the marketplace how, say BCBS, was to know who was or was not entitled if the marketplace had inadvertently termed policies, etc. The marketplace had no response to this except that they could file an appeal with the marketplace or pay the premiums requested and get the money back when they file their 2015 taxes assuming they are eligible for same.

Issue 2: Marketplace inputting incorrect data on new marketplace applications. We have found error after error on policy information which policies were reprocessed by the marketplace. The following are some examples:

a. Tobacco users:
Our clients who's initial policy had them as a tobacco users paying tobacco rates, are now non tobacco users paying a non tobacco rate. This could become an issue as it provides the carrier with a potential reason to rescind that policy.

b. Gender Issues
Men are listed as women and women as men which will cause issues when it comes to submitting and processing claims.

c. Dependents being omitted from the new policy:
In many cases where there are multiple people on a policy, either a spouse or a child is being left off of the new policy. Since the tax credit has either been adjusted or completely removed from these policyholders, it may not be apparent if someone is missing from the policy until some time has passed. This could cause major issues for a family during a great time of need.

Issue 3:
I can only imagine this will cause an invoice nightmare for the carriers.

I am not sure there is anything I am asking for per se but just wanted to make you aware of what is going on out here as knowledge of this could only benefit everyone.

Additionally, this may just be the first round of this as the people currently effected are January 1st effective policyholders. As the information deadlines approach for each other group of marketplace policyholders, I am sure we will see much more of the same in the next several months.

If there is anyway to bring a good resolution to this major issue sooner rather than later that would be a good thing. Otherwise, there are going to be alot of very unhappy and uninsured individuals.

As an agent now I must scramble around and try to find another carrier for my clients to enroll as if they are unable to afford all of the back premiums, they will not be able to keep their current policy."
 
Great post Lisa, and welcome to the forum. It confirms a LOT of what we are all experiencing. I had another client get burned today.


Thank you for posting this information. I sent an email today and they responded very quickly and said they are working to find the best resolution. They asked to give them a little time while they looked into it and would advise with a resolution.

The following was my email to them with what I learned today:

"It is our understanding the Marketplace recently received 2014 Income Tax Information from the IRS.

When reviewing our book of business with various carriers, we have noticed quite a number of marketplace policies terming 04/30/15 (premium with APTC) with a new policy becoming effective 05/01/15 (full premium with no APTC). In addition, our clients are now receiving letters advising them they did not send in documents to prove their income thus their tax credit is being taken away from them.

Not only have these clients sent in the documentation, they have each mailed the documents several times and have also uploaded the documents to their marketplace account well before the requested due date of the documents. However, when they reach out to the marketplace, the marketplace is never able to confirm whether or not they have received the requested documents let alone whether or not the documents were sufficient. Each time the marketplace advises, "if we need anything else we will send you a letter advising of same" or "if the documents are not sufficient, you will receive a letter explaining specifically what is needed."

A marketplace representative advised this morning healthcare.gov is not able to differentiate policies, effective dates, etc. It was initially set up to flag policies when new data came in from the IRS to show inconsistent information for previous year's policies. The following is what the marketplace advised was supposed to have occurred recently:

Policies with an original 2014 effective date-
when these were submitted in 2014, the applicants provided income information as far as their 2014 income and projected 2015. The marketplace just received 2014 data from the IRS. The system should have looked at only people who had policies effective in 2014 to search for inconsistent information; however, rather than dividing people into policy year and application date of 2014 or 2015, the system is looking at everyone who has a policy through the marketplace.

Even though the marketplace used 2014 data to assist in determining whether or not someone would qualify for a Tax Credit for tax year 2015, the marketplace has taken 2014 data and readjusted or removed completely the monthly Tax Credit for these individuals even though most of these individuals have sent in to the marketplace documentation illustrating their change in MAGI from 2014 to 2015.

The marketplace advised this morning even though these individuals may have submitted the requested documents, the system is not recognizing this and just simply utilizing their 2014 IRS data. The marketplace advised they are aware of this issue.

Their recommended resolution for now:
Have each person reapply through the marketplace due to a change of income which would make their new policy effective date 06/01/15. (The policyholder would be responsible for the entire premium for the month of May.) The marketplace advised it was okay that they would owe the entire premium for May as they would "get that money back" when they file their taxes for 2015 so no need to worry.

Issue 1 : Policyholder owing back premiums for the Tax Credit applied to their policy for months January - April:

Currently the carriers have not generated updated invoices for any of these policyholders for May. Once the invoices are generated, the new invoices should request the full premium for May as well as the amount of APTC paid on their behalf for the months of January, February, March and April. (Meaning if someone was receiving a Tax Credit of $500.00 per month, the updated May invoice would reflect their entire May premium along with a balance of $2,000.00 for APTC). These types of monies may be difficult for some people to come up with to keep their policy active. If these individuals do not pay the carriers for these tax credit amounts that were advanced to them and now being invoiced to them, their policy will terminate for non payment.

When I brought this to the attention of the marketplace and asked about this, their response was, "OOOHHHHHH." One marketplace rep said the carrier would not request the monies back especially "if the individual was entitled to the tax credit." So I asked the marketplace how, say BCBS, was to know who was or was not entitled if the marketplace had inadvertently termed policies, etc. The marketplace had no response to this except that they could file an appeal with the marketplace or pay the premiums requested and get the money back when they file their 2015 taxes assuming they are eligible for same.

Issue 2: Marketplace inputting incorrect data on new marketplace applications. We have found error after error on policy information which policies were reprocessed by the marketplace. The following are some examples:

a. Tobacco users:
Our clients who's initial policy had them as a tobacco users paying tobacco rates, are now non tobacco users paying a non tobacco rate. This could become an issue as it provides the carrier with a potential reason to rescind that policy.

b. Gender Issues
Men are listed as women and women as men which will cause issues when it comes to submitting and processing claims.

c. Dependents being omitted from the new policy:
In many cases where there are multiple people on a policy, either a spouse or a child is being left off of the new policy. Since the tax credit has either been adjusted or completely removed from these policyholders, it may not be apparent if someone is missing from the policy until some time has passed. This could cause major issues for a family during a great time of need.

Issue 3:
I can only imagine this will cause an invoice nightmare for the carriers.

I am not sure there is anything I am asking for per se but just wanted to make you aware of what is going on out here as knowledge of this could only benefit everyone.

Additionally, this may just be the first round of this as the people currently effected are January 1st effective policyholders. As the information deadlines approach for each other group of marketplace policyholders, I am sure we will see much more of the same in the next several months.

If there is anyway to bring a good resolution to this major issue sooner rather than later that would be a good thing. Otherwise, there are going to be alot of very unhappy and uninsured individuals.

As an agent now I must scramble around and try to find another carrier for my clients to enroll as if they are unable to afford all of the back premiums, they will not be able to keep their current policy."
 
And another issue with terminating the policy the client has had and reentering: they have already met their deductibles. Many of these people have also met the maximum out of pocket for the year and they have to start all over.

Many issues to work out for sure. "This system is not a well thought-out plan." This comment was made by a specialist I spoke with at the marketplace. We finally agree on one thing at least.
 
Has anyone encounter this issue with termination due to “not sending in documents”. I have a client who was dropped from his household policy. They said he and only he was cancelled due to not sending in his documents. The original effective date was 03-01-2015. When I spoke with the Marketplace CSR they said that if they do not receive the documents (which were already sent in twice) within in 90 days after the original application is submitted they will cancel the policy. (90 days has not yet passed).
The insurance policy is still enforce with only the wife remaining on the policy. He was yanked from the policy and is barred from being added back to the policy until he sends in his documents “again”.
Has anyone else had family members removed individually from a policy or in most cases do they cancel the entire policy for the whole family?
 
Has anyone encounter this issue with termination due to “not sending in documents”. I have a client who was dropped from his household policy. They said he and only he was cancelled due to not sending in his documents. The original effective date was 03-01-2015. When I spoke with the Marketplace CSR they said that if they do not receive the documents (which were already sent in twice) within in 90 days after the original application is submitted they will cancel the policy. (90 days has not yet passed).
The insurance policy is still enforce with only the wife remaining on the policy. He was yanked from the policy and is barred from being added back to the policy until he sends in his documents “again”.
Has anyone else had family members removed individually from a policy or in most cases do they cancel the entire policy for the whole family?

We've seen individuals removed. The only time it seems to happen is when the client needs to send in proof of being here legally. Keep in mind that this is happening even when clients have sent in documentation.
 
Has anyone encounter this issue with termination due to “not sending in documents”. I have a client who was dropped from his household policy. They said he and only he was cancelled due to not sending in his documents. The original effective date was 03-01-2015. When I spoke with the Marketplace CSR they said that if they do not receive the documents (which were already sent in twice) within in 90 days after the original application is submitted they will cancel the policy. (90 days has not yet passed).
The insurance policy is still enforce with only the wife remaining on the policy. He was yanked from the policy and is barred from being added back to the policy until he sends in his documents “again”.
Has anyone else had family members removed individually from a policy or in most cases do they cancel the entire policy for the whole family?

Yes: one of everything has happened. I had the wife terminated because she had not sent in her citizenship documents. She said she had never gotten a letter. I looked in their file and I do not see letters sent to them either.
 
I had a client in this situation, but she was never asked for "documentation" for income for 2015. She didn't make enough in 2014 for the tax credit, so her subsidy disappeared, deductible went up, and Coventry went ahead & took $700/mo for her via EFT for the last 3 months, since the subsidy was gone. She's been totally broke since they wiped out her bank account. She'd also met her deductible due to a broken ankle at the beginning of the year, and now she has a big deductible. She can't afford the insurance at all now. Marketplace says they will re-enroll her (and of course, take me off of the account). I don't know what they think they can re-enroll her in since she can't afford full premium on any of it. So, she's probably going to just get short term & see if they make her pay the penalty next year. . . . .Just awful. . . . .
 
I had a client in this situation, but she was never asked for "documentation" for income for 2015. She didn't make enough in 2014 for the tax credit, so her subsidy disappeared, deductible went up, and Coventry went ahead & took $700/mo for her via EFT for the last 3 months, since the subsidy was gone. She's been totally broke since they wiped out her bank account. She'd also met her deductible due to a broken ankle at the beginning of the year, and now she has a big deductible. She can't afford the insurance at all now. Marketplace says they will re-enroll her (and of course, take me off of the account). I don't know what they think they can re-enroll her in since she can't afford full premium on any of it. So, she's probably going to just get short term & see if they make her pay the penalty next year. . . . .Just awful. . . . .

Yes; that is just awful. I am wondering with all of this if we should encourage direct bill? I took my son off of bank draft for this very reason. Sure enough: his subsidy was decreased this month and absolutely nothing has changed with him. I've never seen anything so sloppy/messy. (Your client can use financial hardship not to have to pay the penalty next year ... thank you very much, not so ACA.)
 
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