An exchange is supposed to eject people who
appear to be dually enrolled about 30 days after sending them warning notices.
By Allison Bell | February 21, 2019 at 03:44 AM
The Affordable Care Act public exchange system is making a change that
could help some people avoid tax nightmares but cause some other people to
suffer a sudden, unexpected loss of ACA exchange plan health coverage.
The public exchange programs will be automatically ending the exchange plan
coverage of many exchange plan users who appear to have Medicare coverage.
Officials from the Centers for Medicare and Medicaid Services (CMS) talk
about the new, automatic expulsion effort in a guide to the “periodic data
matching” effort that was released Wednesday.
The Background
The ACA exchange plan program gives low-income and moderate-income people a
way to use ACA premium tax credit subsidies to help pay for coverage.
Medicare is a federal health insurance program that serves people ages 65
and older, many younger people who qualify for Social Security Disability
Insurance benefits, and people who need kidney dialysis.
Under federal law, people are not supposed to use ACA premium tax credit
subsidies and have Medicare coverage at the same time. ”Double dippers”
may have to return any ACA premium tax credits they received while on Medicare,
when they file their federal income tax returns.
CMS and the exchange programs have been trying to locate ACA
exchange-Medicare double dippers every year since 2015.
The 2019 Change
The 2019 Medicare periodic data matching will probably be different,
because CMS now has better data matching information technology, officials say
in the new Medicare data matching program guide.
The new technology “allows the exchange to take action and end a
consumer’s [ACA subsidies] if they’re found to be dually enrolled in
Medicare and an exchange health plan,” officials say. “Beginning in 2019, the
exchange will now also end exchange health plan coverage for consumers who
permit the exchange to take this action if they’re found to be dually enrolled
at a later date.”
Nuts and Bolts for Agents
Here are some 2019 Medicare data matching program details that could be of
interest to producers who are trying to help consumers understand data matching
program notices, or resolve coverage cancellation problems.
In some cases, an ACA exchange will cancel a suspected double dipper’s
exchange plan coverage along with the subsidy money.
The exchange may cancel a suspected double dipper’s exchange plan
coverage automatically if the suspected double dipper gave the exchange
permission to do so, by saying “yes” to a question in the exchange application.
An affected consumer will have 30 days from the date the notice is sent to
respond to the notice.
If a consumer has given an exchange permission to cancel double dipper exchange
plan coverage automatically, then the exchange can cancel the suspected double
dipper’s ACA subsidies, and health coverage, after the 30-day response window
has ended.
Consumers may give an exchange permission to end their exchange plan health
coverage, as well as their ACA subsidy support, automatically, if the exchange
discovers that the consumers are Medicare-exchange plan double dippers. The
question authorizing automatic coverage terminations is in the exchange program
application.
Exchanges may send Medicare periodic data matching notices throughout the
year.
Consumers who believe that they are still eligible to keep their coverage
in place can file appeals. A consumer must send the appeal to the U.S.
Department of Health and Human Services’ Marketplace Appeals Center.
“Consumers will receive instructions on how to appeal the exchange’s
determination in the final [periodic data matching] notice outlining the action
that the exchange will be taking,” officials say in the data matching program
guide.
Resources
A copy of the Medicare data matching guidance is available here.
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