The ACA-mandated PCIP was created as a temporary high-risk health pool to provide health coverage to eligible uninsured individuals with pre-existing conditions, set to expire on Jan. 1, 2014. However, as a result of the troubled exchange rollout, CMS allowed states to extend PCIP coverage through April 30. While some states transitioned PCIP enrollees in January, an unknown number of states will continue their programs through April.

Since the standard open enrollment period for exchange plans has ended, CMS is providing a SEP in the Federally-Facilitated Exchange (FFE) for individuals who are losing PCIP to avoid a lapse in coverage. The SEP allows PCIP enrollees to select a plan until June 30. If the consumer is otherwise eligible to enroll in a QHP, coverage will be effective back to May 1. State-Based Exchanges (SBEs) are also adopting similar SEPs.

This move by CMS will allow for greater continuity of care for individuals with serious pre-existing conditions and may modestly contribute to post open enrollment registration. Although CMS says that the majority of PCIP enrollees have already transitioned to the exchanges, insurers may see a slight increase in the proportion of May and June SEP enrollees with significant health needs. Issuers must be prepared to provide retroactive coverage for these individuals up to two months before registration.

View CMS’ SEP announcement.