Health Care Reform Questions – Enrolling in the Marketplace This Fall

By Larry Grudzien
Attorney-At-Law

Question:  I enrolled in my employer’s group medical coverage at its open annual enrollment on July 1, 2014. In November 2014, I plan to drop this medical coverage and enroll in Health Insurance Marketplace at its next open enrollment for 2015.  Can I drop my employer’s group medical coverage in November 2014 for coverage on the Health Insurance Marketplace for 2015.
 
Answer: No. You may not drop coverage in the middle of a plan or policy year unless you incur a qualifying event specified in in the employer’s cafeteria plan.  Enrolling in the Health Insurance Marketplace is not considered a qualifying event for 2015.
 
IRS provided transitional relief in the proposed employer mandate regulations allowing employees in noncalendar year group medical plans to drop coverage and enroll in coverage in the Health Insurance Marketplace for January 2014, if the employer amended its cafeteria plan to allow it.   
 
This transitional relief has not been extended to enrollments on the Health Insurance Marketplace for 2015 or any other future year.

Question: My employer is having its open annual enrollment in a few weeks for its health coverage effective on July 1, 2014. If I do not enroll in my employer’s health coverage effective July 1, 2014 and voluntarily drop it, can I then enroll in health coverage on the Health Insurance Marketplace because of a loss of coverage?

Answer: No. If you voluntarily drop your employer sponsored coverage or lose it because you did not pay the premium, you do not qualify for a special enrollment period for a loss of coverage. This means you will not be able to get covered through the Marketplace until the next open enrollment period in November 2014, with coverage starting January 1, 2015.

To be considered a loss of coverage for a special enrollment period to apply, you must lose health coverage because you quit your job, had a reduction of hours o are laid off. In other words, you lost eligibility for the employer health coverage.

The annual open enrollment period for 2015 is set to begin November 15, 2014 and extend through February 15, 2015. Coverage will be effective January 1, 2015 only for applications received by December 15, 2014.
       
For More Information: If you have any comments or questions regarding any of above information, please do not hesitate to call me at (708) 717-9638 or e-mail me at larry@larrygrudzien.com