On December 12, 2013, with twelve shopping days until Christmas and three shopping days left until exchange enrollment was supposed to close for 2013, HHS, citing “unforeseen barriers to enrollment in the Exchanges,” issued an interim-final rule entitled “Maximizing January 1, 2014 Coverage Opportunities.” The rule formally extends until December 23, 2013, the date by which individuals must enroll in the exchanges to ensure coverage for January 1, 2014, giving applicants eight additional shopping days. The rule also extends until December 31 the date by which enrollees must pay their premium to ensure coverage for January 1, while the preface encourages insurers to give enrollees even more time to pay, or to accept partial payments. The preface to the rule encourages insurers to help ensure continuity of provider coverage and availability of off-formulary drugs.
Finally, another notice, also released on December 12, extends coverage in the Pre-existing Condition Insurance Program (PCIP), which was supposed to expire on December 31, 2013, for one month.
The troubles that have afflicted the Healthcare.gov federal exchange website and many state exchanges are common knowledge. Although enrollment is going more smoothly now, millions of uninsured individuals who are eligible for advance premium tax credits that will largely cover the cost of their coverage have not yet been able to enroll. Millions of additional individuals have been unable to renew their current policies in the individual and small group market, as those policies do not meet 2014 market reform requirements. Although these individuals can purchase policies in the individual and small group market outside of the exchange, and most of them probably will, many would be able to find better deals in the exchange or qualify for premium tax credits but have not yet been able to do so.
In addition, 105,000 individuals are covered through the PCIP and a couple of hundred thousand more through state high risk pools, which were supposed to have closed at the end of 2013. These individuals desperately need coverage. The interim final rule attempts to extend the opportunities all of these individuals have to gain coverage.
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