This is a continuation of the Special Enrollment Period verification conversation from earlier in the week. I am of the opinion that the new CMS requirement for eligibility verification for the four major qualifying events is a reasonable accomodation to insurer’s needs to promote a more stable market and for people with legitimate qualifying events, not a significant barrier. Someone I greatly respect disagrees.
— Claire McAndrew (@claire_mcandrew) February 25, 2016
- Loss of minimum essential coverage
- Permanent move
- Adoption, placement for adoption, placement for foster care or child support or other court order
From my perspective, the triggering event produces official paperwork in four of the five scenarios and that paperwork arrives very quickly. It is not a case of an individual needing to find an original birth certificate from halfway across the country. Is my middle class privilege overwhelming reality here? I don’t think so, but I need a reality check
The loss of minimum coverage triggers a COBRA eligibility letter if the loss of coverage is because of a job loss that had ESI. If an individual makes too much for Medicaid or otherwise loses Medicaid/CHIP, a termination letter with appeals rights is sent. If the loss is due to the non-payment of premium, termination letters are sent. This is recent paperwork.
Birth of a new baby produces lots of poop and a birth certificate.
Marriage produces a marriage license. Divorce produces a divorce decree. Both of those documents are freshly produced after 1/1/16.
Adoption, foster care, adoption placement, and child support produces reams of legal documentation and orders. And again, this is fresh documentation after 1/1/16.
The hardest one to prove for some people is permanent move. Middle class individuals can easily produce a signed lease or a mortgage or several bills at a distinct address. However, people who are far less connected to the system may be using informal housing arrangements without leases or documentation, and they may only have a few bills and no bank account. Those bills could be paid online and thus it would not matter if they all still went to a parent’s address 2 states away as they always were thrown away. This is a challenge in my mind, but that is the only QE that is not guaranteed to produce recent verification documentation.
Does this make sense?