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Marketplace special enrollment verification update

In May, we posted an article about the Marketplace Stabilization rule announced by the Centers for Medicare and Medicaid Services (CMS). If you have not read the first update on the Marketplace Stabilization rule, we recommend you do so here

The Consumer and Retail Markets division promised to share with you any CMS updates when they arrive. Our most pressing Marketplace Stabilization questions were focused on the new special enrollment period (SEP) verification process, as highlighted in the last article. As such, we were anxious for more information. You can see the full CMS presentation on the SEP verification process here, which we highly recommend you review if you’ve not done so already. We also wanted to bring a couple of key updates to your attention. 

A new SEP process

Beginning June 23, 2017, expect to see a different process when you enroll your clients through the FFM, which is Phase 1. On June 23, a special enrollment verification issue (SVI) will trigger for “loss of coverage” and “permanent move” for new Marketplace applicants with a new application. Existing enrollees who attest to SEP qualifying life events won’t be subject to pre-enrollment verification.

When an SVI is triggered, your client will be notified that they need to send the corresponding documents to confirm their qualifying life event. The notification, called an Eligibility and Determination Notice (EDN), will explain your client’s requirement to resolve the SVI that was triggered, and lay out the acceptable documents and deadlines to submit. The client has 30 days to resolve the SVI once they’ve selected a plan.

On August 1, the FFM will deploy system updates to pend and create additional SVIs for “marriage,” “adding a dependent” and “CHIP/Medicaid Denial.”

Like other types of SEP issues that require a client to send additional information to verify the enrollment, your client will need to verify the qualifying life event before the application is approved.

Again, we advise you review the full presentation from CMS. Just like today, you’ll still be able to submit SEP enrollments through the Direct Enrollment Pathway via Blueprint for Agents and the Blue Solutions Tool. But there will be some key differences:

SVI Chart