A proposal to shift the Affordable Care Act’s annual enrollment period could both help and hurt consumers, according to state insurance regulators and industry officials.
There are still three weeks left in the current enrollment period, but insurance companies already are scrambling to prepare their 2016 plans and rates because the federal government wants future enrollment periods to run from Oct. 1-Dec. 15.
That would help uninsured consumers avoid tax penalties because those who sign up by Dec. 15 in any one year would be assured of having coverage for the entire next year. But the proposal is also creating short-term problems for insurance companies, who now face short deadlines to submit their plans and rates, and for state regulators who review them.
Northeast Delta Dental offers coverage in New Hampshire, Maine and Vermont, and officials in all three states are concerned about meeting the ramped up deadlines, said Christine Alibrandi, the company’s project leader for healthcare reform.
“It raises a question of, while a longer open enrollment on its face seems like it’s good, does it need to be as long as it as?” she said at a recent meeting of New Hampshire’s Health Exchange Advisory Board. “Even if it got pushed back two weeks or a month … that gives an extra cushion on this already condensed timeline.”
Lisa Guertin, president of Anthem Blue Cross and Blue Shield of New Hampshire, said the proposed deadlines aren’t impossible, but they shift some focus away from what should be the top concern right now: taking care of new customers who are enrolling now.
“The way it’s blurring together, I think we’re pushing it,” she said. “I think it starts to bleed into this (enrollment) period in a way that ultimately isn’t great for consumers.”
For example, she and others noted that insurance companies won’t have much 2015 claims data or other information on hand as they develop their 2016 products, networks and rates.
“They should want a price that’s not any higher than it should be or any lower than it should be,” she said of consumers. “This makes that harder.”
New Hampshire isn’t alone — the National Association of Insurance Commissioners raised similar concerns in a recent letter to the CMS. The potential problems may be felt more keenly in New Hampshire, however, for several reasons.
While Anthem has dominated New Hampshire’s individual market for years and is in its second year of offering plans under the Affordable Care Act, others just entered the market this year. Sean Caron of Minuteman Health said the compressed schedule puts his company and other newcomers at a huge disadvantage.
“We have no data to go off of, other than what we have seen in those first couple of months,” he said.
In his own letter to CMS, New Hampshire Insurance Commissioner Roger Sevigny said he worries the abbreviated timeframes could deter some companies from offering plans altogether. That would be particularly problematic for New Hampshire, which had just one company selling health plans for 2014 and five for this year.
“Higher levels of competition generally help to prevent premiums from increasing as quickly as they might otherwise,” said department attorney Jennifer Patterson.
Further complicating matters in New Hampshire is the fact that the state is still waiting for federal approval to use Medicaid money to buy private insurance for low-income adults. Companies participating in the Affordable Care Act marketplace will have to be prepared to accept those enrollees but won’t likely know until March whether the waiver has been approved, leaving them little time to adjust their plans, Patterson said.
The CMS declined to discuss New Hampshire’s specific concerns but said it is reviewing all submitted comments on its proposal. In the proposed rule itself, the agency says it believes the altered enrollment period would provide consumers with sufficient time to enroll and would be less confusing because it doesn’t cross calendar years.