Special Annual Open Enrollment

There is an Open Enrollment Period from 11.15 to 12.15 where a Small Group can enroll without meeting participation or contribution requirements. “Final Rule” (2.27.2013 13416 Federal Register Vol 78 gpo.gov

Specific Insurance Company Rules  2015 Rules (Word & Brown)  Kaiser – Very General Info    Warner Pacific – Requires Log In

Blue Shield Info through 3.31.2016

Your firm may still have issues with Management Carve Out Section 2716 Health Care Reform – as you must treat all employees the same,  and must still offer insurance to all employees…  I don’t think this provision is that big a deal, as at renewal, you MUST meet the participation & contribution rules!

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The Guaranteed Issue Special Open Enrollment period runs from November 15th to December 15th each year for a January 1st effective date.

Carriers are required to offer a special open enrollment window to Small Employers that do not meet carrier participation and/or contribution requirements. These groups must meet all other Underwriting Guidelines. Small Employers that have struggled to attain coverage due to participation or contribution requirements can obtain coverage during this special open enrollment window.

The guide below summarizes our carrier partners’ deadlines and other important details such as whether or not the listed carrier must be the sole carrier for the group.

Although carriers must lower their contribution requirements, the Affordable Care Act still mandates that Applicable Large Employers (ALEs) with 50 or more full-time plus full-time equivalent employees must offer affordable coverage that meets minimum value in order to avoid a 4980H(b) employer penalty. IRS common ownership/controlled group rules apply when determining whether or not an employer is an ALE. The Affordability Safe Harbor Percentage for 2017 is 9.69%

Health Plan Special Open Enrollment Guidelines
Aetna
  • Must be the sole carrier confirmed by an attestation form
  • Groups must be complete at submission with all requirements in by 12/15. No exceptions for missing items
  • Recertification at renewal: Yes, to ensure group meets the definition of a small employer
Anthem Blue Cross
  • Must be the sole carrier
  • Groups must be complete at submission with all requirements in by 12/15. No exceptions for missing items
  • Recertification at renewal: No; Special Open Enrollment Window groups will not be targeted for a participation audit, however they could be recertified at random
Blue Shield of California
  • Does not require to be the sole carrier
  • Case must be approved within 30 days of submission or it will be withdrawn
  • Recertification at renewal: Yes, groups will need to meet minimum participation requirements upon renewal
CaliforniaChoice
  • Must be the sole carrier
  • Case must be approved by: 12/31
  • Contingent approvals will not be allowed
  • Recertification at renewal: carrier discretion
Health Net
  • Does not require to be the sole carrier
  • Cases must be received by Health Net by 5:00 pm on 12/15
  • Case must be approved by: 1/20
  • Recertification at renewal: carrier discretion
UnitedHealthcare
  • Does not require to be the sole carrier with staff model carrier. UHC requires at least 5 CA employees to enroll with UHC
  • Groups must be complete at submission with all requirements in by 12/15. No exceptions for missing items
  • Recertification at renewal: Yes, all groups are subject to recertification annually
Sharp Health Plan
  • Must be the sole carrier. Sharp will write alongside a cross border plan. Cross border plans are considered valid waivers.
  • Case must be approved by: 12/15, no exceptions
  • Recertification at renewal: carrier discretion

 

Other pages in the Participation & Contribution Requirements section

 

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