On May 2, 2014 HHS issued a new bulletin. This bulletin provides a “special enrollment” period until July 1, 2014 for individuals who have already elected COBRA continuation coverage. This new rule will allow those who have already elected COBRA continuation coverage to drop their COBRA coverage and select a potentially lower priced QHP – “Qualified Health Plan” on or off the exchange at any time before July 1, 2014.
Before this new bulletin was published, those eligible for COBRA continuation coverage only qualified for a special enrollment period when they first become eligible for COBRA or when they exhausted their COBRA continuation coverage (typically 18 months later). This new rule only applies to states that have a “Federally Facilitated Exchange” like the state of Illinois. See if your state has a “Federally Facilitated Exchange” click here
Those with 2013 Individual health plans that renew in 2014 now qualify for a “Special Enrollment” period.
The new May 2, 2014 bulletin also allows those who purchased 2013 plans from the ‘old market’ to qualify for a ‘special enrollment’ period if their 2013 plan renews in 2014. The applicants can apply for a QHP up to 60 days before their plans terminate and they may also apply up to 60 days after their plan’s renewal date. In this April 8, 2014 article I noted that before this new bulletin Assurant Health was the only carrier that was offering a QHP to those with plans from the ‘old market’ outside of ‘open enrollment’ periods. With this new May 2, 2014 bulletin all carriers will eventually need to comply. As of the date of this writing Blue Cross Blue Shield of Illinois had not stated when they will comply. If and when they do I will add their statement to this post.
New options for those with Americorps, VISTA or National Civilian Community Corps
This new bulletin also creates a third new ‘special enrollment’ period when members of these programs begin their service and when their service ends. Since members of these programs are often times under-insured on plans that do not contain “minimum essential health benefits” this bulletin grants a hardship exemption from the ‘individual responsibility’ TAX for non compliance. That per person TAX in 2014 is either $95 or 1% of your MAGI – Modified Adjusted Gross Income.