2015 NY State of Health Open Enrollment Potential Problems

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2015 Health Insurance Open Enrollment in NYSOH begins on November 2, 2014 for Small Businesses and November 15, 2014 for Individuals and Families. With this being the first ‘Open Enrollment’ period since the new healthcare law has been in effect, there are many questions and concerns being raised on how the renewal process will work and what problems businesses and individuals should be on the lookout for. In this article, I look to show common questions asked and answered by NYSOH as well as what you should be on the lookout for at renewal.

Question: Does NYSOH know how the member renewal process will work?
Answer: NYSOH is developing an administrative renewal process for those Qualified Health Plan (QHP) members that consented to allowing the Marketplace to access electronic records for the purpose of determining eligibility in future years. Marketplace consumers will have the option during the
open-enrollment period, which starts on November 15, 2014. Marketplace consumers will
have the option to remain in their current qualified health plan for calendar year 2015. The
Marketplace intends to provide a notice to current Marketplace members informing them of
this option. This notice will be provided closer to the open enrollment period.

Question: Will insurers be allowed to auto renew individuals in their individual products offered
outside the Marketplace?
Answer: Questions related to off –Exchange renewals should be directed to the NYS
Department of Financial Services. (subsequent calls to NYSDFS confirm off exchange or outside marketplace individuals will be offered the option to auto renew into the same plan at renewal since there are no subsidy qualifications in effect and they will just pay the new premium rate as of 1/1/15)

One potential pitfall for NYSOH enrollees will be the process of ensuring these individuals receive the correct amount of financial help for 2015 and are enrolled in a plan that meets their needs and budget. These enrollees will need to update their information on their NYSOH member portal to make sure they are receiving the proper subsidy.

On the Federal Marketplace, the fine print of a recent HHS announcement said consumers who auto enroll will get the “the exact dollar amount” of financial aid they are receiving this year. NYSOH has not announced what their process will be for subsidy amounts in 2015 for renewing plans, but either way it’s likely to be a problem for a couple of reasons:

First, subsidies are partly based on premiums for a current benchmark plan in the community where the consumer lives. Because insurers are submitting entirely new bids for 2015, the benchmark in many communities will be different.

Second, subsidies are based on household income. If your income goes down, you are entitled to a bigger health insurance tax credit. If it goes up, you get less. The 2014 amounts could well be out of date and incorrect for many people.

While some advocates say auto renewal is a safeguard to keep some people from falling through the cracks if they forget to choose a plan, I would recommend every enrollee review their finances during this year’s renewal process to see if the subsidy they received last year will change and if so, please contact their broker to assist them in choosing a renewal plan that best fits their needs.