WAHBE PREMIUM SPONSORSHIP PROGRAM For 2015 Coverage Year Background In 2010, Congress passed and President Obama signed the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act (ACA), which in part creates health insurance exchanges. The ACA allows Indian tribes, tribal organizations, and urban Indian organizations to pay Qualified Health Plan (QHP) premiums on behalf of their tribal members who are enrolled in health plans in the commercial market, subject to terms and conditions determined by each state exchange (See 45 CFR 155.240(b)). In 2012, the Washington Legislature passed Engrossed Second Substitute House Bill 2319, which furthers implementation of the state-based Washington Health Benefit Exchange (WAHBE). E2SHB 2319 directs the Exchange Board to establish policies that permit city and county governments, Indian tribes, tribal organizations, urban Indian organizations, private foundations, and other entities to pay premiums on behalf of qualified enrollees (See RCW 43.71.030(3)). These entities are known as Sponsors.1 The procedures below describe how Sponsors will be able to pay the unsubsidized2 portion of the premium for qualified enrollees of a QHP through Washington Healthplanfinder. Registration Process Sponsors must complete and submit to the Exchange a form that provides the following information: Sponsor contact information Conditions of program participation (if any) Name(s) and contact information for authorized Sponsor Representatives o Sponsor Representatives will be able to authorize payment information on behalf of the Sponsors in the Healthplanfinder. 1 The Exchange is willing to work with any entity interested in paying premiums on behalf of qualified individuals. However, certain public or nonprofit organizations, or certain public funds, might not be legally authorized to make individual insurance premium payments. Each entity that would like to be a Sponsor will have to determine whether they have the authority to spend funds for premium payments. 2 People purchasing a Qualified Health Plan (QHP) through Washington Healthplanfinder may be eligible for government subsidies (through a tax credit) that can lower the cost of their premiums. Health Insurance Premium Tax Credits (HITPCs) will be provided to people with a family income between 100% and 400% of the Federal Poverty Level (FPL). The most that these families buying subsidized coverage in an exchange will pay towards a health insurance premium will range from 2.01% of income at 100% of poverty to 9.56% of income at 400% of poverty. HITPCs will be paid by the federal government directly to the insurance issues to lower the cost of premiums. o o Sponsor Representatives will be required to attend a training on managing Sponsorship payments in Healthplanfinder, complete security training, and complete a background check.3 In-Person Assisters or Tribal Assisters4 may perform Sponsor Representative functions upon request of the Sponsor. Sponsors may cover the premiums for an individual, household, or one or more members in a household. Sponsors are also allowed to sponsor premiums for any plan they choose. Sponsor Representatives may inform individuals which plans are sponsored, but when selecting a plan the individual must be shown all available plan choices. If an individual chooses a plan, tier, or issuer that is not included in the sponsor’s list of supported plans, the sponsor is not required to sponsor that enrollee’s premium payment. Conflict of Interest If a Sponsor Organization receives any compensation, directly or indirectly, from a health insurance issuer for enrolling individuals or employees in insurance coverage, then the Sponsor Organization must disclose that fact to the Exchange and the sponsored individuals at the time of enrollment. Sponsorship Duration So that WAHBE may effectively support the sponsorship of household accounts, each entity must commit to sponsoring an enrollee for no less than 6 months. Exceptions to this durational requirement based on unexpected events will be considered on a case-by-case basis (e.g., a Sponsor experiences a sudden financial shortfall). Note: Each Sponsor may have program eligibility requirements that impact an individual’s continued eligibility (e.g., only cover individuals up to 300% of FPL). This duration requirement does not apply if the sponsored individual fails to comply with a Sponsor’s rules of participation. Copies of Correspondence Sponsor Representatives, if granted permission by the sponsored enrollee, can receive an electronic notice each time there is an invoice, correspondence, or update to the enrollee’s Healthplanfinder account and access these correspondences (See Appendix I for list of enrollee correspondence).5 3 For a Sponsor Representative to provide application and enrollment support, the representative must meet additional training requirements and pass a qualifying examination. 4 To become an authorized representative for a sponsoring organization, an in-person or tribal assister would complete an additional sponsorship-specific training module(s). 5 Sponsorship representatives who will be ‘linking’ to individual accounts will need to sign an agreement that indicates that individual account information will not be shared or misused. A Sponsorship Representative is distinct from an “Authorized Representative.” All policy notifications from the health insurance issuer will be sent directly to the individual enrolled with the issuer. Sponsored individuals will also be billed directly for any out of pocket costs, such as copays or deductibles, or their share of covered services provided. Payment Requirements Premium payment(s) will be made by Sponsors directly to Healthplanfinder on behalf of the sponsored enrollee(s). To complete the initial enrollment for sponsored enrollees, the Sponsor representative will need to initiate payment on their behalf. For the initial payment the Exchange will accept credit cards, debit cards, or e-checks.6 No transaction fees will be incurred for electronic payments. Sponsor account or credit card information will not be viewable by the sponsored individual. Sponsors must cover the entire premium payment after any eligible health insurance premium tax credit has been applied.7 No partial premium payments are allowed. The sponsor must pay the full invoice amount (for all household members seeking coverage through a single application). For example, if three members in a family enroll together in a qualified health plan, the sponsor would need to cover all enrollees in that household. If a sponsor only wants to sponsor one member of a household, this household member will need complete a separate application seeking coverage only for him/herself. Sponsor payment information must be entered for each QHP enrollment household or individual that is being sponsored. This information can be entered by a Sponsor Representative who is with the sponsored enrollee or at a different off-site location, if the sponsored enrollee has granted permission for the Sponsor Representative to access his/her account.8 A Sponsorship Representative can set up a monthly recurring electronic payment for each sponsored enrollee, so the Sponsor account information only needs to be entered once. Recurring payments are processed each month on the date designated by the Sponsorship Representative. Recurring Payments can only be made using the eCheck option (savings or checking account), after the initial payment has been posted. If the recurring payment is set up before 5pm it will take effect the following business day. A Sponsor is always able to remove their sponsorship, by deleting payment information or no longer providing it. The Sponsor is responsible for notifying individuals who are being removed at least 15 business days before the next payment is due. 6 After an initial electronic payment, paper checks/money orders/cashier’s checks with Remittance Coupons will also be accepted. QHP enrollees may also pay their premium contribution directly to their QHP issuer. 7 Sponsor organizations may want to consider requiring individuals to apply the maximum amount of HIPTC to their monthly premium. In Healthplanfinder, if an individual is determined to be eligible for a tax credit he/she then selects how much of the subsidy to apply towards their premium amount each month. 8 Sponsorship representatives who will be ‘partnering’ to individual accounts will need to sign an agreement that account information will not be shared or misused. Payment Process 9 Open enrollment period begins November 15, 2014 and extends through February 15, 2015. 9 Enrollment Completed Coverage Effective Date On or before December 23, 2014 January 1, 2015 January 1-23, 2015 February 1, 2015 February 1-15, 2015 March 1, 2015 Initial payment is entered in the Healthplanfinder by the Sponsor Representative. This payment amount will be in the amount of the first month's premium payment. For the initial payment, the Sponsorship Representative will choose a date between 12/1/14 and 12/23/14 when the initial premium payment will be withdrawn. Sponsor Representatives can also set up recurring payments. Recurring payments are processed each month on the date designated by the Sponsor Representatives. An email address is required to set up recurring payments. Recurring payments can only be made using the eCheck option after the initial payment has been posted. After coverage begins, invoices will be sent to enrollees on the 1st of the month based on their selected communication preference (electronic or postal mail). For example, an invoice will be sent on March 1st for the April 1st-30th coverage period. The individual payment is due by the 23rd of each month (March 23 in this example). The Exchange will generate a receipt when a premium payment is made through Healthplanfinder. Key Bank will be responsible for processing payments and sending electronic payments to issuers on behalf of covered individuals. A sponsored enrollee is responsible to ensure their premium payment was successfully made. If a premium payment is not made on behalf of the sponsored enrollee, delinquency, grace period and termination could occur. In these cases the enrollee must submit premium payment to the Exchange to be removed from delinquency status. o If payment is not received or is invalid due to insufficient funds, the Exchange will send a delinquency notice to the enrollee on the 1st of the month in which a payment for that month was not received. o Households that are receiving Health Insurance Premium Tax Credits are eligible for a 3month grace period to make payments, beginning on the 1st of the month following a missed payment.10 If a payment is not made during the 90 day grace period, coverage will terminate effective the last day of the first month in the grace period. American Indians and Alaska Natives (AI/ANs) are not subject to open enrollment restrictions and may enroll in the Exchange at any time during the year. Individuals with Special Enrollment Periods (SEPs) may also enroll after open-enrollment ends. 10 Qualified Health Plan (QHP) households not receiving HIPTC have a 1-month grace period. If payment is not made during the 30 day grace period, they will be disenrolled effective the last day of the month prior to their grace period. For example, if an enrollee fails to make payment for the coverage period of April 1- April 30, coverage will terminate effective March 31. For example, enrollee fails to make payment by March 23rd for the coverage period of April 1- April 30. If no payment is made during their April 1 – June 30 grace period, coverage will terminate effective April 30. The QHP issuer is required to pay claims during the first month of a grace period, but may suspend claims in the second and third months. Exchange Services Related to Premium Sponsorship For the individual market, the Exchange will aggregate the premium contributions of QHP enrollees, and transmit those aggregated premium payments to the appropriate issuer. The federal government will coordinate payments of the HIPTC (and cost-sharing reductions) directly with the issuers. The Exchange will provide staff to manage the sponsorship process, provide training for Sponsor Representatives, and grant access so Representatives can initiate payment on behalf of the sponsored individuals. As needed, the Exchange will also generate periodic reports to assist Sponsors with budgeting and future planning. Sponsorship Timeline for 2015 Coverage Year ▪ ▪ ▪ ▪ ▪ ▪ ▪ 11 September—WAHBE hosts a Premium Sponsorship webinar with Sponsors October—Sponsors identify authorized Sponsorship Representatives who are not also Tribal Assisters, Navigators, Certified Application Counselors (CAC), or In-Person Assisters (IPA) September—Tribal Assisters, Navigators, Certified Application Counselors (CAC), or In-Person Assisters (IPA) receive training October—Sponsorship Representatives receive training Fall—Sponsors conduct outreach to sponsored individuals Nov 15-Dec 23—Enroll sponsored individuals for coverage effective January 1, 2014 February 15, 2015—Open enrollment ends11 American Indians and Alaska Natives (AI/ANs) are not subject to open enrollment restrictions and may enroll in the Exchange any time during the year. Individuals with Special Enrollment Periods (SEPs) may also enroll after open-enrollment ends. Appendix I: QHP Enrollee Correspondence Below is a list of enrollee correspondence that the Exchange will be responsible for sending: Eligibility Decision for Health Care Coverage notice: The Exchange will send individuals an eligibility determination notice that specifies what programs the primary applicant and the other members of the household are eligible for including Medicaid, Apple Health for Kids, APTC, or QHP. Monthly Invoice: The Exchange will invoice enrollees in the individual market on the 1st of the month prior to the month of coverage. Receipt of Payment: The Exchange will generate a receipt of payment for individuals when enrollees make a premium payment through the Exchange. Premium Payment Delinquency notice: The Exchange will send a delinquency notice to the enrollee on the 1st of the month in which a payment for that month was not received. Health Benefit Termination notice: In a disenrollment scenario, the Exchange will send the enrollee a Health Benefit Termination notice which states the day that their coverage in an Exchange QHP will end or did end if retroactively disenrolled. Yearly Advance Premium Tax Credit Summary notice: The Exchange will provide enrollees who are eligible for APTC a yearly notice that summarizes the amount of APTC they received for the previous tax year. Upcoming Open Enrollment Deadline notice: During Open Enrollment the enrollee will receive an Upcoming Open Enrollment Deadline notice which states the beginning and end date for Open Enrollment and prompts the enrollee to select and enroll in a Plan for the next coverage period. This correspondence will not be sent during the initial open enrollment period. Upcoming Special Enrollment Deadline notice: If an enrollee is eligible for a Special Enrollment Period and has not selected a plan, the Exchange will send the enrollee an Upcoming Special Enrollment Deadline notice to prompt them to return to the Exchange to select and enroll in a plan. This notice also explains to the enrollee that if they do not update their plan selection they may be disenrolled from coverage.
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