as per the nice, smart and highly competent Humana rep... she is working on this issue. She does agree that a problem exist..... why did no one at the insurance companies foresee this problem before we on the forum did???
Humana ACA Commissions/New Rates
- Thread starter FLM2
- Start date
You were alert and on top of things, TaterPeeler, to see that a problem exists. This is a problem for more than one carrier, because many carriers are planning to auto-enroll current clients in an ACA compliant plan if the client does not make an election with their current carrier. It's unfortunate that a program designed to protect the client has a glitch. Let's work with the carriers to fix that glitch.
And for those that posted that they don't see the glitch, I hope MAPD agents who work with SEPs a lot can make it clearer. Those of us who do group insurance are familiar with qualifying events and COBRA elections, and those who do MAPD are familiar with SEPs. The problem is the election. From what I understand, you can make several elections in OEP and the last OEP election is the one that stands. But you can only make one election in an SEP.
In this case, the OEP is over, and an SEP is generated when the pre-ACA plan terminates at its 2014 renewal date. So if a carrier (be it Humana, BCBS, or any other carrier) defaults to auto-enroll those people in an ACA compliant plan at that point, they have just made the election for that SEP. That election cancels out the client's choice of another carrier, and that SEP election is the final one.
In our efforts as agents, and the carriers efforts, to protect the client in cases where it appears the client made no elections, we don't want to inadvertently hurt the client. And we don't want to file for a "wrongdoing SEP" which is where CMS or the exchange gets a complaint from the client saying that the agent or the carrier put the client in the wrong plan. I applaud any carrier that works with us to fix this.
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Oh, and one more clarification. For those who said to just terminate the current carrier's coverage, remember that a voluntary termination does not open an SEP. So, unless you have other insurance in force, and terminate the current plan well in advance of the end of OE (12/7/2014), you will go a year without coverage.
And for those that posted that they don't see the glitch, I hope MAPD agents who work with SEPs a lot can make it clearer. Those of us who do group insurance are familiar with qualifying events and COBRA elections, and those who do MAPD are familiar with SEPs. The problem is the election. From what I understand, you can make several elections in OEP and the last OEP election is the one that stands. But you can only make one election in an SEP.
In this case, the OEP is over, and an SEP is generated when the pre-ACA plan terminates at its 2014 renewal date. So if a carrier (be it Humana, BCBS, or any other carrier) defaults to auto-enroll those people in an ACA compliant plan at that point, they have just made the election for that SEP. That election cancels out the client's choice of another carrier, and that SEP election is the final one.
In our efforts as agents, and the carriers efforts, to protect the client in cases where it appears the client made no elections, we don't want to inadvertently hurt the client. And we don't want to file for a "wrongdoing SEP" which is where CMS or the exchange gets a complaint from the client saying that the agent or the carrier put the client in the wrong plan. I applaud any carrier that works with us to fix this.
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Oh, and one more clarification. For those who said to just terminate the current carrier's coverage, remember that a voluntary termination does not open an SEP. So, unless you have other insurance in force, and terminate the current plan well in advance of the end of OE (12/7/2014), you will go a year without coverage.
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Ann are you saying that if a 2013 IFPlan renews in say, July 2014, the client will need to cancel their Non-ACA compliant plan and wait until the 2014 Open Enrollment period to obtain an ACA-compliant health plan because they cancelled the Non-ACA plan voluntarily in July 2014? This is getting deeeep. haha.
-Allen
Good point, Allen. I was thinking about end-of-year renewals, but what about mid-year 2014 renewals. I already thought voluntary termination would be unwise at the end of the year, but it would be worse mid-year. Voluntarily termination would mean there is no SEP, and the OE is months away. So, let's work with carriers to fix this. All we need is a carrier-designed form saying, "No, please do not default to automatically enrolling me in an ACA compliant plan upon the end of my pre-ACA plan." This would be an option chosen by clients who wish to purposefully enroll in the plan of their choice (which may be with another carrier), during the SEP that is created when their pre-ACA plan ends. And, in your example, Allen, that could be July 2014 in many cases.
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On SEP with MA's...it depends on what the SEP is for. Example if the client is a Medi Medi they can change anytime. Or if they have LIS. Now if they move into a new area that's an SEP so they sign up for a new plan they change their mind and want another plan they can as long as they do so before the effective date. So the long and short of it is, what is the SEP for makes all the difference. Hope this helps.
and kevin, that's the point.... it will be a loss in coverage sep... they have one shot
also, the effective date in the humana case will be the next day
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If they don't get this fixed people will be up in arms over this. I want to believe this was an oversight and not some chicanery on their part.
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They get one shot in ma sep. my point was after you have found the plan you want for 2014/15 what ever year you going into. So next year going into 2015 find the plan that works best for you on the exchange after you get enrolled send the cancelation into your current company stating do not renew and cancel on 12-31 xx I would fax it personally so you have proof of receipt cms is on the side of the consumer so If their is proof what plan they were enrolling in and dis enrolling from cms will make the correction
Okay, and Anonymous1, you've recommended that approach several times. Not to be combative or anything, but isn't a carrier-produced form with the "do NOT automatically enroll me in an ACA-compliant plan" option better? Any way you cut this, sending in a cancellation letter leaves the client with a time period that they have no coverage. If their renewal is 7/1/2014 like AllenChicago said, they have 6 months with no coverage if they send in a voluntary cancellation notice. That's because a voluntary cancellation doesn't trigger an SEP. If it's Humana's option, where their current plan ends 12/30/14 and is auto-enrolled in ACA 12/31/14, they must cancel by 12/7 when open enrollment is still available, leaving them 24 days with no coverage. Actually, they would want to cancel effective 12/1 to make sure the earned premium isn't buying them coverage until the end of that month. Sure, there are short-term plans to cover this gap, but once again, isn't a carrier-produced opt-out form a much better answer? I'm sure the carriers will fix this glitch once they become aware of the problems it will cause with an enormous number of clients who want to make their own choices rather than being auto-enrolled.
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If they pick a plan to start 1-1 from the exchange in oct fax a letter to the existing company to tell them not to auto enroll them/ do not renew/ cancel. On 12-31-xx year my assumption was for those with a new 1-1 start date moving forward. For those in July I do not know the correct answer I would assume that those plan will end with no fault of the enrolled and will have the option to enroll to a new plan via sep and the in oct will have the chance to pick another new plan for a 1-1 effective date This is how Ma works although I have not had a ma plan end mid year.
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While I'm thinking of this since they enrolled after 12-7 would the coverage start 1-1 or 2-1 because it is an sep if for what ever reason they did get auto enrolled into a plan they did not choose So their first selection during aep starts 1-1 and the sep starts 2-1 I'm just trying to follow the train of thought on this I have no answer on this
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While I'm thinking of this since they enrolled after 12-7 would the coverage start 1-1 or 2-1 because it is an sep if for what ever reason they did get auto enrolled into a plan they did not choose So their first selection during aep starts 1-1 and the sep starts 2-1 I'm just trying to follow the train of thought on this I have no answer on this
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