Creating SEP with a Short Term
- Thread starter Zanetti90
- Start date
- 8,448
So as to not reinvent the wheel, I refer you to:
http://www.insurance-forums.net/forum/health-insurance-reform-forum/stm-plans-sep-t68542.html
ac
http://www.insurance-forums.net/forum/health-insurance-reform-forum/stm-plans-sep-t68542.html
ac
Cigna is allowing this for off exchange business, I have no idea whether their decision is compliant or not
I think AZ (Ann? Y? Chime in here) has a co-op allowing year round SEPs.
And it makes actuarial sense.
Client goes through underwriting to get the STM plan. Then signs up for an indy. So the carrier gets more healthy people to add to their indy pool.
Its probably not legal. But I haven't seen what executive orders were signed this morning.
- 1,304
Loosing non essential coverage (STM) does qualify you to get coverage off exchange with many carriers.
Oddly enough every QLE that we did in 2K14 specifically with the marketplace, no proof was required aside from a verbal claim that the QLE occurred. I don't recall one enrollment requesting that from the subsidy determinations we've come across.
Has anyone else had to provide proof to the exchange that a QLE occurred?
Could it be that "Open Enrollment" is just a Government marketing strategy to boost enrollments during that specific time period while still allowing clients to be written outside of these time frames?
Oddly enough every QLE that we did in 2K14 specifically with the marketplace, no proof was required aside from a verbal claim that the QLE occurred. I don't recall one enrollment requesting that from the subsidy determinations we've come across.
Has anyone else had to provide proof to the exchange that a QLE occurred?
Could it be that "Open Enrollment" is just a Government marketing strategy to boost enrollments during that specific time period while still allowing clients to be written outside of these time frames?
- 8,448
After studying the IRS instructions for Form 8965 ( Instructions for Form 8965 (2014) ), I've changed my mind and conclude that a Short Term Medical Health Insurance Policy does indeed meet requirement for Minimum Essential Coverage, for every month the client has it in effect.
Until the IRS or HHS states that STM is not minimum essential coverage, the door to using a 1 STM for triggering SEP enrollments is wide open, and legal. Furthermore, clients who have STM are exempt from the Shared Responsibility Penalty for the months the Short Term Medical Insurance policy is in effect.
This is how I'm going to operate, unless I find, or someone shows me IRS, HHS, DOL, etc.. wording that forbids it.
-ac
Until the IRS or HHS states that STM is not minimum essential coverage, the door to using a 1 STM for triggering SEP enrollments is wide open, and legal. Furthermore, clients who have STM are exempt from the Shared Responsibility Penalty for the months the Short Term Medical Insurance policy is in effect.
This is how I'm going to operate, unless I find, or someone shows me IRS, HHS, DOL, etc.. wording that forbids it.
-ac
Insurancenoob
New Member
- 5
Will definitely be looking into this one. I was under the understanding that STM plans don't qualify for minimum essential coverage for a number of reasons. Preexisting exclusion, maximum benefits, denial of coverage, no maternity benefits and the list goes on. As my name states, I haven't been in the business long but I can read and this one seems like a no brainer. I was actually astonished/excited at the prospect when I saw this post and was compelled me to make my 2nd post ever. But i saw nothing in that link that even remotely looked like an STM loophole. Hope your E&O is up date and let us know how that works out for you.
Last edited:
- 1,304
Minimum Essential Coverage
It states clearly that STM is NOT Minimum Essential coverage.
https://www.google.com/search?q=aca+minimum+coverage&oq=ACA+Mini&aqs=chrome.3.69i57j0l5.7416j0j7&sourceid=chrome&es_sm=122&ie=UTF-8#q=aca+is+short+term+medical+insurance+minimum+essential+coverage
If you look even the carriers state clearly that STM is not Minimum Essential Coverage.
It states clearly that STM is NOT Minimum Essential coverage.
https://www.google.com/search?q=aca+minimum+coverage&oq=ACA+Mini&aqs=chrome.3.69i57j0l5.7416j0j7&sourceid=chrome&es_sm=122&ie=UTF-8#q=aca+is+short+term+medical+insurance+minimum+essential+coverage
If you look even the carriers state clearly that STM is not Minimum Essential Coverage.
- 483
From healthcare.gov:
Important: If you leave your job for any reason and lose your job-based health coverage, you qualify for a Special Enrollment Period. But you don’t get an SEP if you voluntarily drop: a job-based plan without leaving your job; an individual insurance plan; unexpired COBRA coverage; or any plan that doesn’t qualify as minimum essential coverage
https://www.healthcare.gov/coverage-outside-open-enrollment/special-enrollment-period/
I, for one, am not comfortable signing someone up for a STM for a month with the promise of obtaining a SEP after.
Important: If you leave your job for any reason and lose your job-based health coverage, you qualify for a Special Enrollment Period. But you don’t get an SEP if you voluntarily drop: a job-based plan without leaving your job; an individual insurance plan; unexpired COBRA coverage; or any plan that doesn’t qualify as minimum essential coverage
https://www.healthcare.gov/coverage-outside-open-enrollment/special-enrollment-period/
I, for one, am not comfortable signing someone up for a STM for a month with the promise of obtaining a SEP after.
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