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Covered California Q&A

Covered California and Obamacare related questions from consumers, employers and agents are answered by Phil Daigle with the best information available at the time. Archived entries may no longer be accurate as the Covered California and Obamacare knowledge-base is evolving quickly. TO REQUEST A PERSONAL RESPONSE INCLUDE EMAIL ADDRESS.


SEP for Individual Plan Renewals?

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Question: I just got a rate increase on my grandfathered individual plan. It going up 24% effective July 1st. Can I still buy an Obamacare plan?

Answer: Yes. This is a qualifying event for a Special Enrollment Period (SEP). According to Covered California, “You have a health insurance plan outside of Covered California, and your renewal date is not between Nov. 15, 2014, and Feb. 15, 2015, or future open enrollment dates and you would like to switch to a Covered California health insurance plan instead of renewing your current plan.” Here’s how it will work: You can apply for coverage either through Covered California or directly with the insurer of your choice when your non-calendar-year individual plan renews. You can report to your insurer that you will not renew their plan up to 60 days before the renewal date. Your current carrier must provide a limited open enrollment period beginning on the date that is 30 calendar days prior to the date the policy year ends in 2014 to select and ACA-compliant individual plan. If you choose to enroll through Covered California, you will have up to 60-days from the renewal date to select a plan in the exchange. Reference: https://www.coveredca.com/coverage-basics/special-enrollment/qualifying-life-events/

2 Comments

Steve, pull a quote on your HN agent site and you will see a screen pop-over with reference to Qualified Events. HN states as Phil has cited here.

For non-calendar year plan renewal Qualifying Events, Assurant is providing enrollment 60 days prior and 60 days after. Not sure about the two Blues and Kaiser yet.

Yet Covered California is behind the curve per usual, as it is providing enrollment at only 60 days from the DATE of the Qualifying Event, which means that when one enrolls through Covered California with a off-calendar-year Qualifying Event, one should actually ride-out their current off-calendar-year Grandfathered plan for at least one more month while the CovCal application is ‘processing,’ because the soonest available effective date Covered California will provide is at minimum one month forward from day one of the Qualifying Event.

Another enrollment/QE issue I’ve been dealing with is even more difficult, and inappropriate, and as I understand it, in conflict with existing continuous-coverage law. Enrollment through Covered California for an enrollee with involuntary loss of Group coverage as their Qualifying Event is guaranteed a FORCED minimum one month GAP IN COVERAGE.

Covered California repeatedly insists than an enrollee with a loss of group coverage QE cannot apply and enroll PRIOR to their QE date. Therefore and thereby, upon application through Covered California, one can attain coverage as soon as only the first day of the following month. The enrollee will be without continuous coverage for at minimum one month, and possibly two or three months if applied for day 16 through 60 within the entire 60 day QE allowance.

Typically COBRA enrollment, and HIPAA plan enrollment, provides and provided 63 days to enroll in a plan with coverage made effective retroactively to the first day of such plan eligibility. Continuous coverage is and was provided.

It appears, the organization intent on getting people covered has established a mandate in violation of HIPAA and COBRA which were passed with intent to provide enrollees access to continuous health insurance coverage.

CovCal reps and managers just don’t get it about this forced gap-in-coverage liability when someone loses group coverage.

With involuntary loss of Group coverage, enrollment through Covered California should be provided at least 30 days, if not 60 days, PRIOR to day one of this Qualifying Event… so as to provide an enrollee the ability to obtain continuous health insurance coverage.

Or (even ‘and’) there needs to be an enrollment option for retro-active coverage back to the first day of QE eligibility, to be provided when an enrollee applies from day one forward of their 60 day Qualifying Event.

Do you have a citiation? The closest I can find is http://www.cms.gov/cciio/Resources/Regulations-and-Guidance/Downloads/complex-cases-SEP-3-26-2014.pdf

http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/SEP-and-hardship-FAQ-5-1-2014.pdf

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