In response to the COVID-19 pandemic, the Biden administration announced a Special Enrollment Period (SEP) for the federally facilitated marketplace. This edition of A Kansas Twist summarizes key events leading to the SEP, discusses how the federal American Rescue Plan Act of 2021 impacted marketplace premiums and the financial assistance available to consumers, and looks at the Kansas-specific data in the 2021 Final Marketplace Special Enrollment Period Report (2021 SEP Report) released by the U.S. Department of Health and Human Services (HHS) on Sept. 15, 2021. These data update information contained in a June 21, 2021, KHI issue brief that provided summary data about Kansans who selected health insurance or stand-alone dental plans through the federally facilitated marketplace, HealthCare.gov, during the 2021 Open Enrollment Period (2021 OEP).
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The 2021 Special Enrollment Period
On Jan. 28, 2021, President Joe Biden signed Executive Order (EO) 140009 to “protect and strengthen Medicaid and the ACA [Affordable Care Act],” and as a result, HHS, through the Centers for Medicare & Medicaid Services (CMS), announced the SEP, which would begin on Feb. 15, 2021, and run through May 15, 2021. The SEP would allow individuals without qualifying life events (QLE) to enroll in ACA marketplace plans outside of the annual open enrollment period. On March 11, 2021, the President signed the American Rescue Plan Act of 2021 (ARP) into law, which included provisions implemented on April 1, 2021, that expanded the eligibility for APTCs to consumers with household incomes over 400 percent of the federal poverty level (FPL), who were ineligible for APTC assistance under the ACA, and increased the APTC available to households with incomes between 100 and 400 percent of FPL. The increased APTC took the form of lowering of the cap on the percent of income enrollees are required to spend for their health insurance premiums from 9.83 to 8.5 percent.
On March 23, 2021, President Biden announced that CMS would extend the SEP from May 15, 2021, to Aug. 15, 2021, and would allow individuals and families, including those who had not experienced a QLE, to enroll or re-evaluate their coverage needs with the increased tax credits made available under the ARP. CMS also announced an additional marketplace subsidy under the ARP, effective July 1, 2021, for individuals who were approved for unemployment compensation benefits for any week beginning in 2021. This allowed unemployed individuals to enroll in a $0 or very low-cost silver plan with Cost-Sharing Reduction (CSR) subsidies that reduce their out-of-pocket costs when using the benefits of the plan. The changes announced by CMS provided an opportunity for individuals to get access to insurance coverage outside of the annual enrollment period, and further allowed individuals and families that had already enrolled during the 2021 OEP that ended on Dec. 15, 2020, to reevaluate their coverage and enroll in a different plan to take advantage of the expanded tax credit provisions of the ARP.
The 2021 Final Marketplace Special Enrollment Period Report
In the 2021 SEP Report released on Sept. 15, 2021, HHS reported that 2,069,596 Americans in the 36 states using HealthCare.gov enrolled in new marketplace health insurance coverage during the SEP that ended on Aug. 15, 2021, including 21,220 Kansans. These consumers were defined as those who did not have an active enrollment as of Feb. 14 and made a plan selection on or after Feb.15 that was still active as of Aug. 15.
The Report also identified existing consumers who had an active enrollment as of March 31, 2021 (meaning a non-cancelled plan with an end date of Dec. 31, 2021) and made a new plan selection on or after April 1, 2021. This included consumers who actively reselected their existing plan, those who selected a new plan, and those who had their premiums automatically reduced effective Sept. 1, 2021, by HealthCare.gov as a result of an automatic redetermination of their APTC. HHS reported that the 8,017,151 Americans identified as existing consumers in all 50 states experienced a 50 percent reduction in their average monthly premium after APTC and an average monthly premium savings of $67 due to the ARP APTC expansion. The Report also noted that the total monthly aggregate savings for these existing consumers was more than $537 million. The Report identified 57,857 Kansans as existing consumers and reported a 48 percent reduction in their average monthly premium after APTC and average monthly premium savings of $63 a month. The total monthly aggregate savings for these existing Kansas consumers was $3.6 million.
The 2021 SEP Report also included data for the 2,069,596 consumers in the HealthCare.gov states who enrolled in new coverage showing that 48 percent of these new enrollees made plan selections with monthly premiums of $10 or less after APTC, had average monthly premiums after APTC of $81, and average monthly APTCs of $468. The Report did not provide state-specific data for these categories.
Finally, HHS reported that nationwide 208,622 consumers made a plan selection or went through automatic redetermination that made them eligible for additional APTC under the ARP’s unemployment compensation provisions. State-specific data also was not provided for this benefit category.
The three APTC enhancements provided under the ARP are temporary. The first two – new subsidies for higher income households (over 400 percent FPL) who did not qualify for APTC prior to the ARP, and the reduced insurance premium cap of 8.5 percent of income – will remain available on HealthCare.gov through 2022. The enhanced APTCs and CSRs for individuals who were approved for unemployment benefits during 2021 will end on Dec. 31, 2021.
For the 2022 Plan Year, a Final Rule announced by CMS on Sept. 17, 2021, will add an extra 30 days to the 2022 OEP and future benefit years. The 2022 OEP will run from Nov. 1, 2021, through Jan.15, 2022, on HealthCare.gov. The Final Rule also establishes a new monthly special enrollment period on HealthCare.gov for consumers with projected annual household income no greater than 150 percent of FPL.