As we’ve written, the Department of Health and Human Services (HHS) has imposed new requirements on people trying to enroll in health plans through the federal marketplace during special enrollment periods (SEPs) despite scarce data showing that consumers are inappropriately using SEPs. The new rules pose substantial risks that many people eligible for SEPs won’t be able to get needed coverage. Fortunately, HHS can take steps to lower these risks.
The new rules require people enrolling outside the open enrollment period to submit paperwork proving that they qualify for an SEP because of a life change such as getting married, having a baby, moving, or losing other health coverage. But some people who may qualify for an SEP might not have the needed documents or understand what they need to submit.
That’s already happened to many people asked to prove their citizenship or immigration status or their income when applying for marketplace coverage. In 2015, about 470,000 people lost marketplace coverage and over 1 million households lost some or all of their subsidies to help pay for coverage because they had problems proving their eligibility.
To reduce the risk that eligible people won’t be able to enroll when they experience a life change, HHS should:
Allow consumers to prove their eligibility with a broad array of documents. The fact sheet announcing the new requirement mentioned birth and marriage certificates. But these documents aren’t usually available until weeks after the life-changing event, so HHS should allow people to submit other forms of proof, such as hospital records.
Also, HHS should make special efforts to ensure that people who recently moved and don’t have utility bills or leases, such as migrant farmworkers, survivors of domestic violence, or people living with friends or family can enroll. And, in some situations, it may be hard for people losing their jobs to get a letter from their employers in advance or even afterwards, so HHS should allow people to submit statements or other forms of proof.