Blue Cross and Blue Shield of Illinois

 

November 1, 2013

Legislative Update
Open Enrollment and Special Enrollment Periods on Get Covered Illinois, the Official Health Marketplace of Illinois

The opening of Get Covered Illinois, the Official Health Marketplace of Illinois provides access to purchase individual products for people who may not have previously had access to health insurance.

While many people will continue to keep employer-sponsored coverage, some may have lost their coverage, or simply want to explore their options on the Marketplace.

Open enrollment for individual coverage for eligible U.S. citizens and legal residents on the Marketplace extends from Oct. 1, 2013, to March 31, 2014.

Once open enrollment ends, there are still certain circumstances someone may be able to apply for coverage on the Marketplace outside of the Marketplace open enrollment dates. Here are some FAQs about open enrollment, special enrollment periods and COBRA.

Q: When does coverage on the Marketplace take effect?

A: Since  open enrollment for 2014 will last longer than usual — from Oct. 1, 2013, to March 31, 2014 — the effective date of an individual’s health insurance coverage will depend on when he signs up for a plan:

  • Enrolls on or before Dec. 15, 2013 – coverage will be effective on Jan. 1, 2014.
  • Enrolls between the first and 15th of any subsequent month – coverage will be effective on the first day of the following month. For example, an individual enrolls Jan. 5, 2014; coverage will start on Feb. 1, 2014.
  • Enrolls between the 16th and the last day of any month between Dec. 1, 2013, and March 31, 2014 – coverage will be effective on the first day of the second following month. For example, an individual enrolls on Feb. 22, 2014; coverage will start on April 1, 2014.

After this initial open enrollment, the open enrollment period will begin on Oct. 15 and end on Dec. 7 of each year and coverage will be effective Jan. 1 of the following year.

Q: What if a person’s situation changes and he needs health care coverage? Can he go to the Marketplace outside of the open enrollment period?

A: If a person loses his job or has another qualifying life event, he may qualify for a special enrollment period on the Marketplace. A person will qualify if:

  • He loses minimum essential coverage.
  • He gains a dependent or becomes a dependent through marriage, birth, adoption or placement for adoption.
  • He becomes a citizen, national or lawfully present individual.
  • He is eligible to enroll, but didn’t because of a mistake, misrepresentation or inaction of an officer, employee or agent of the Marketplace.
  • The plan he enrolled in substantially violated a material provision of its contract with the individual.
  • He becomes newly eligible for premium tax credits or cost-sharing assistance.
  • He becomes ineligible for premium tax credits or cost-sharing assistance.
  • He makes a permanent move and has access to new health plans.
  • He is a member of an American Indian tribe. (American Indians can enroll in a plan or change plans one time each month.)
  • He demonstrates to the Marketplace that he has other extenuating circumstances that qualify him for special enrollment.

When any of these situations happen, he will have 60 days to go to the Marketplace to enroll in a health insurance plan or change plans.

If he buys insurance directly from Blue Cross and Blue Shield of Illinois, he can update his information online in Blue Access for MembersSM or by calling the number on the back of his member ID card. If he loses his coverage during the year, he can also qualify for a special enrollment period on the Health Insurance Marketplace (subject to certain exceptions, including loss of coverage for failure to pay premiums on a timely basis).

Q: If a person is covered as an individual in the Marketplace, can he decide to drop his Marketplace coverage at any time and come back on the employer-sponsored group plan?

A: The qualifying events for an individual to be eligible for the group coverage plan are the same qualifying events as listed above. There must be an open enrollment or a qualifying event in order for the employee to come back on the group health plan.

Q: If a person has employer-provided coverage, can he seek coverage on the Marketplace? 

A: Yes, a person with employer-provided coverage may seek coverage on the Marketplace. However, if the person is eligible for employer-sponsored coverage that is affordable and meets minimum value, he may not be eligible for the premium tax credit and cost-sharing assistance on the Marketplace. He should also review his employer's eligibility rules before making a decision about the coverage option that is right for him.

Q: What if an employee is not on the group plan and is not eligible until open enrollment of May 1, 2014? Can he obtain coverage on the group plan effective for Jan. 1, 2014, or does he have to wait for open enrollment? If he has to wait until open enrollment, will he face a penalty?    

A: Affordable Care Act regulations state that an individual is not liable for a penalty for lack of carrying minimum essential coverage until they have had an opportunity to enroll in the employer's health plan if they will be eligible during the annual open enrollment. For example, in this case, because the employee is eligible for his group plan, but open enrollment does not begin until May 1, 2014, he will not face a penalty for not having minimum essential coverage. However, he will not be able to enroll in his employer’s coverage until May 1, 2014.

Q: How will the Affordable Care Act affect COBRA eligibility?

A: The Affordable Care Act did not eliminate COBRA or change the COBRA eligibility rules.

Q: If a person loses his job, can he retroactively get coverage on the Marketplace? For instance, if he loses his job and his coverage ends on Feb. 1, can he buy an individual plan on the Marketplace on March 1 and be covered retroactive to Feb. 1?

A: No. If a person purchases coverage on the Marketplace on March 1, it would begin on April 1.

Q: If a person loses his job on Feb. 1, can he go on COBRA until he can purchase a plan on the Marketplace and it becomes effective? For instance, if he loses his employer coverage as of Feb. 1, can he purchase an individual plan on the Marketplace that goes into effect on March 1, but accept and pay for COBRA for February?

A: Yes. In this scenario, a COBRA-eligible employee can carry COBRA coverage until his new Marketplace Qualified Health Plan is effective on March 1.

Q: Can someone drop COBRA coverage to get Marketplace coverage at any time?

A: No. A person can only drop COBRA coverage to switch to Marketplace coverage during the open enrollment period. Outside of the open enrollment period, a person can seek Marketplace coverage once his COBRA coverage expires.

This communication is intended for informational purposes only. It is not intended to provide, does not constitute, and cannot be relied upon as legal, tax or compliance advice. The information contained in this communication is subject to change based on future regulation and guidance.

 


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A Division of Health Care Service Corporation, a Mutual Legal Reserve Company,
an Independent Licensee of the Blue Cross and Blue Shield Association.