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Insights

Dec 17, 2013

CMS Codifies Enrollment Deadline Delay

Published

Dec 17, 2013

On Dec. 12, CMS released an interim final rule (IFR) codifying recently announced changes that permit consumers to enroll in health insurance coverage through an exchange as late as Dec. 23 for coverage effective Jan. 1, 2014.

This change affords consumers an additional eight days relative to the original deadline of Dec. 15. CMS is also permitting issuers of qualified health plans (QHPs) to accept premium payments beyond Dec. 31, 2013—the earliest allowed payment deadline — for coverage effective Jan. 1, 2014.

In addition, the IFR strongly encourages qualified health plans (QHPs) to adopt voluntary transitional policies aimed at ensuring continuity of provider relationships and prescription drug therapies for new enrollees including: A significant amount of pressure is being put on health insurance issuers to help to mitigate the effects of the technical issues with healthcare.gov that have resulted in delays and barriers to enrollment on the exchange. While many of these proposed transition policies are voluntary for issuers, CMS is clearly signaling that they expect issuers to comply, such as through indications that QHP renewal may be tied to QHP’s efforts to ensure continuity of coverage through transitional periods. However, many of these policies — announced less than a month before the start of coverage on Jan. 1, 2014 — will require significant operational changes on the part of issuers or require issuers to assume increased risk.    

  • Treating out-of-network services as having been received in-network with respect to any provider listed in the version of the provider directory as of the date of the enrollee’s enrollment for the beginning months of coverage;
  • Considering a provider as in the plan’s network for an acute episode in January;
  • Covering non-formulary drugs as if they were on-formulary, or covering formulary drugs without imposing prior authorization or step therapy requirements, during the first 30 days of coverage, starting Jan. 1, 2014.

In terms of consumers, CMS’ encouragement of transitional medication fills is positive for those who would like to continue on existing therapies and who may have been unable to access the formulary for their new plan to determine whether existing drugs are covered. These transitional policies also should encourage continued medication adherence, while giving patients time to work with providers to meet prior authorization or step therapy requirements.

Comments are due to CMS by 5 p.m. Dec. 23.  The IFR is available here.

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