Andrew Garland: Income-based Special Enrollment Period

Vermont is proposing to expand enrollment of health insurance to allow low-income Vermonters’ access to new plans year-round. Blue Cross supports expanding the special enrollment period to support low-income families and reach more definitively toward health equity.

When people have access to care, they are able to manage their chronic conditions, have access to medication counseling and care management programs, maintain prenatal care, and schedule their flu shots. When more people have care, they have a better quality of life and are able to cross at least one looming challenge off their list.

Currently, everyone must enroll for health plans annually during a window in the late fall, for coverage beginning each year in January. In compliance with federal law, if you miss the deadline or choose to forego health insurance during the enrollment period, the window closes to you until the following year, with some narrow exceptions.

This rule was created with the inception of the Affordable Care Act to prevent “adverse selection” – which is when people wait until they are sick or anticipate significant health care needs (such as a knee replacement) to purchase coverage. Health insurance only works when everyone participates, whether they are well or in need of care, as the premiums paid by everyone are pooled to cover the extraordinary needs of a few every year. We participate in this arrangement because no one ever knows if or when they may be one of those few. While there will always be a concern for the integrity of the pool, extending the special enrollment period for families who qualify for benefits makes sense. We want all Vermonters to have access to preventative care, to manage their chronic conditions, and to see their provider when they are sick. To that aim, we need to eliminate the barriers to coverage.

A new “low-income special enrollment period” recently announced by the Centers for Medicare and Medicaid Services allows individuals and dependents with household income below 150 percent of the federal poverty level (i.e., up to $32,940 for a family of three) to newly enroll in marketplace coverage or change plans. COVID-19 special enrollment rules gave us more latitude to broaden access outside of the normal enrollment period. Experience with similar programs in other states has also proven positive—offering coverage and supporting people through the process of enrolling for low or no-cost premiums support seamless transition to coverage while smoothing out the risk pool they participate in. Lowering the burden of access and affordability is good for the individual and it’s good for the population as a whole.