ACA Marketplace Open Soon for 2024 Enrollment; New Policies Mean Less Red Tape

The Affordable Care Act (ACA) health insurance marketplaces’ open enrollment period for 2024 coverage begins November 1. This is an opportunity for millions of current enrollees to explore plans available on the marketplace and make changes to their coverage for next year and for people in need of coverage to sign up.

Marketplace enrollment broke records in each of the past four years, amid several policy and operational shifts, including increased premium tax credits (PTCs) enacted under the American Rescue Plan and extended through 2025 by last year’s Inflation Reduction Act.

As of February 2023, 15.6 million people had enrolled in an ACA marketplace plan for 2023 and paid the first month’s premium to activate that coverage. The vast majority of enrollees in 2023 (91 percent) are receiving PTCs that reduce or eliminate their premiums, and the average enrollee is paying just $124 per month for their coverage after accounting for PTCs. Among people who chose a 2023 marketplace plan during open enrollment, 6.3 million had income up to 150 percent of the federal poverty level (or about $20,000 for an individual), making them eligible for a silver “benchmark” plan with a zero premium, which means the PTC covers the entire cost of their monthly premium. They are also eligible for silver plans with reduced deductibles and other cost sharing because of federal cost-sharing reductions or CSRs.

This open enrollment season will be an important opportunity for people who have lost Medicaid or Children’s Health Insurance Program (CHIP) coverage to make the transition to marketplace coverage if they are eligible. Most states are in the process of “unwinding” ― reviewing their entire Medicaid caseloads, after a three-year pause in eligibility terminations during the pandemic — which is leading to large numbers of people losing coverage this year. While many may still be eligible for Medicaid or CHIP, some may not be, for instance because they got a job with a higher income or aged out of the program. They can enroll in a marketplace plan and get financial help with premiums and out-of-pocket costs if they qualify.

In states that use HealthCare.gov — the federal marketplace —people who lose Medicaid or CHIP are eligible for a special enrollment period (SEP) to enroll in marketplace coverage at any time through July 2024 (most state-based marketplaces have similar policies in place). However, confusion about the Medicaid unwinding process and limited awareness of the SEP have contributed to low marketplace enrollment rates since unwinding began earlier this year.

The annual outreach and advertising campaigns that accompany the marketplace open enrollment period could drive more people to visit HealthCare.gov or their state’s marketplace to get coverage. And people who qualify for the unwinding SEP don’t have to wait until January 1 for their new marketplace coverage to take effect; it can be effective as soon as the first day of the month after someone selects a marketplace plan (for example, December 1 if someone enrolls in November).

The 2024 coverage year also marks the beginning of several new policies issued by the Centers for Medicare and Medicaid Services (CMS) in its annual marketplace rule:

• More people stand to automatically get plans with reduced deductibles. In HealthCare.gov states, if a person is enrolled in a bronze-level plan but is eligible for a silver-level plan with CSRs, the marketplace will automatically re-enroll the person in a silver-level plan with CSRs if the person does not actively reenroll by December 15. The marketplace will only make this switch if a silver plan is available for the same or a lower premium than the bronze plan and if the plan is offered by the same issuer, is the same type of plan, and has the same provider network as their bronze plan. People will still have until January 15 to change their plan, but this helps ensure people who are eligible for CSRs don’t needlessly pay higher out-of-pocket costs.

• Fewer people will have to resolve data matching issues for income. In the past, if a person applied for marketplace coverage, but the Internal Revenue Service did not have information about the person’s income (for example because they haven’t filed taxes before, haven’t filed recently, or have had a change in household circumstances or filing status), this triggered a data matching issue and the person was required to submit documentation verifying their income.

  Now, if the IRS doesn’t have information about a person, the marketplace will accept a person’s income attestation. This removes a time-consuming administrative barrier and will allow more people to maintain coverage and financial help. And people who do need to submit income verification to resolve a data matching issue for another reason (e.g., their projected income exceeds their prior year’s income by more than the allowable thresholds) will now qualify for an automatic 60-day extension if they do not resolve the issue within the first 90 days.

In addition to these changes, people seeking coverage on HealthCare.gov will once again be offered standardized plans (called “easy pricing” plans on the website), which have the same cost-sharing charges for specific services no matter what insurance company is offering them. These may make it easier for people to compare plans based on remaining differences in premiums, provider networks, and quality ratings.