FAQ: Final STLDI Rules & the Future of Complete, Complete Plus and Short Term Plans
On March 28, 2024, the Departments of Health and Human Services (HHS), Labor and Treasury released final rules for short-term, limited duration insurance (STLDI) coverage. The new rules go into effect on September 1, 2024. Our FAQ provides an overview of how the finalized rules will affect future Complete, Complete Plus and Short Term sales.
Frequently Asked Questions
Q1: What is happening with limited duration plans in 2024?
On July 7, 2023, the Biden administration proposed new rules for short-term plans that would close loopholes on insurance products that provide less coverage than Affordable Care Act (ACA) plans (e.g., plans like Complete & Complete Plus). Under the new rules, all short-term plans would be limited to three months in duration, or a maximum of four months, if extended, per year.
On March 28, 2024, the Departments of Health and Human Services (HHS), Labor and Treasury released final rules for short-term, limited duration insurance (STLDI) coverage. The new rules go into effect on September 1, 2024.
Q2: How will the new rules affect future Complete, Complete Plus and Short Term sales?
Once the new federal rules take effect, we will no longer sell new Complete and Complete Plus plans. We will also discontinue selling Short Term policies.
Q3: What does this mean for current Complete, Complete Plus and Short Term members?
Complete, Complete Plus and Short Term members with coverage in place before the new rules go into effect may keep their existing plans past September 1, 2024, until their plans expire.
Q4: What will happen to Complete and Complete Plus members who have plans expiring sometime in the middle of 2025?
Complete and Complete Plus members who have plans scheduled to terminate in 2025 are strongly encouraged to shop for an ACA plan during the upcoming Open Enrollment Period to avoid a lapse in coverage. Remember, when a Complete or Complete Plus plan ends, it will not trigger a qualifying life event for a person to enroll in an ACA plan.
Q5: When is the last date Arkansas Blue Cross will accept applications for Complete, Complete Plus and Short Term plans?
The last date we will accept new Complete, Complete Plus and Short Term applications will be Monday, July 1, 2024. The last available effective date for these plans will be August 1, 2024.
Q6: Will members on Short Term plans be able to extend their coverage for one more month after the new rules go into effect on September 1?
No. We will discontinue selling Short Term policies after July 1. After this date, no new Short Term plans will be sold and no existing Short Term plans will be able to be extended.
Q7: Why will Arkansas Blue Cross stop selling Short Term plans once the new federal STLDI rules are in place?
To comply with the new rules, carriers must create operational mechanisms to prevent plan “stacking” (e.g., reapplying for a short-term plan multiple times during a 12-month period). The organizational lift required to put this monitoring system in place would be significant, especially considering the timing so close to the Medicare and ACA annual enrollment seasons. Therefore, we’ve decided to stop selling Short Term plans.
Q8: Will agents receive lists of their current Complete and Complete Plus members who are set to expire at any point during 2025?
Yes. Similar to the member lists we distributed for our Complete/Complete Plus special offer in the fourth quarter of 2023, we will compile lists of members with 2025 termination dates. We strongly encourage you to discuss ACA plan options with these members during this year’s ACA Open Enrollment Period.
Q9: What if I have Complete or Complete Plus members whose plans expire sometime in 2026 or 2027? Will they be required to move to the ACA during this year’s ACA Open Enrollment Period?
No. These members can keep their current Complete or Complete Plus plans until they expire in 2026 or 2027.