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THE AFFORDABLE CARE ACT:
ELIGIBILITY & ENROLLMENT
PAGE 2
OVERVIEW
• Eligibility Requirements
• Exchange Enrollment
• Eligibility & Enrollment Verification
• Penalties
• Appeal Process
• Key Dates
PAGE 3
EXCHANGE ELIGIBILITY
PAGE 4
ELIGIBILITY: REQUIREMENTS
• For an individual to qualify for the Exchange they need to:
o Be a U.S. citizen, national, or legal resident
o Must reside in the same state that they are applying for coverage
o For programs that require an income eligibility, income will be
based off Modified Adjusted Gross Income
• An individual is not eligible for coverage through the Exchange if
incarcerated, unless charges are pending
• For CHIP, Medicaid, and Medicare, individual must meet that
program’s specific eligibility requirements
PAGE 5
ELIGIBILITY: EXEMPTIONS
• Individuals must have the minimum level of healthcare coverage
provided or face a penalty
• The following categories provide exemptions for individuals
from this coverage requirement:
o Religious Exemptions
o Undocumented Immigrants
o American Indians
o Financial Hardships
o Incarceration
PAGE 6
ELIGIBILITY: PROHIBITED FACTORS
• Issuers can no longer deny coverage to individuals with
pre-existing conditions
• Issuers are no longer able to drop individuals due to the
diagnosis of serious illnesses
• Issuers are no longer allowed to set annual and/or lifetime
limits
PAGE 7
ELIGIBILITY: GOVERNMENT BASED
HEALTHCARE
Medicaid
• A state-based healthcare program that provides coverage to low-
income households and individuals with disabilities
CHIP
• CHIP is the Children’s Health Insurance Program
Medicare
• A government health insurance program administered by the
Centers for Medicare and Medicaid Services
PAGE 8
ELIGIBILITY: MEDICAID
Medicaid Eligibility Before ACA Medicaid Eligibility After ACA
- Pregnant women and children (<6 years)
whose family income is ≤ 133% of the
Federal Poverty Level
- Children under 19 whose families are at or
below the FPL
- Families with children that meet the Aid to
Families with Dependent Children
- Most Supplemental Security Income
recipients
- Recipients of adoption or foster care
individuals
- Special protected groups
- Certain Medicare beneficiaries
- Certain optional groups
Source: CMS.gov - Brief Summaries of Medicare and
Medicaid and Kaiser Family - Medicaid A Primer
- Eligibility groups streamlined to
- children
- pregnant women
- parents and caretaker relatives
- adults (ages 19-64)
- Income eligibility will be based off modified
adjusted gross income and household
income
- Eligibility based off monthly income at time
of application
- Minimum income eligibility for adults is
133% of FPL
Source: Federal Register - Medicaid Program Eligibility
Changes under the ACA and Kaiser Family - Medicaid and
the uninsured
PAGE 9
ELIGIBILITY: CHIP
• CHIP covers children whose family income is too high for
Medicaid
• The ACA will keep the same eligibility standards in place
through 2019
• The ACA has expanded eligibility beyond the original
requirements of children under 19 and household
incomes of 200%
PAGE 10
ELIGIBILITY: MEDICARE
• Overall eligibility for Medicare does not change with
the enactment of the ACA
• Medicare eligibility requirements include:
o Being a U.S. citizen or legal immigrant
o Being age 65 or older
Source: SocialSecurity.gov Medicare and Proof of Citizenship
PAGE 11
ELIGIBILITY: MEDICARE
Medicare Part Eligibility Requirements
Part A
Individual is eligible if under age 65 and:
- Receives Social Security Disability Insurance for minimum of 24 months,
- Receives disability from Railroad Retirement Board,
- Receives disability due to Lou Gehrig’s disease,
- Has worked 10 years in a governmental job where Medicare taxes were paid and
meet requirements for Social Security Disability; or be the child/widower of
someone who has met those requirements, or
- Has permanent kidney failure or has received a kidney transplant
Individual is eligible if age 65 or older and:
- Receives benefits from Social Security or Railroad Retirement,
- Has an eligible spouse,
- Has worked (either individual or spouse) in a government job where Medicare
taxes were paid, or
- A dependent parent of a fully insured deceased child
Part B - Anyone eligible for Part A can enroll in Part B
- Monthly premium is based off income
Part C - Anyone who is eligible for Parts A and B can enroll in Part C
Part D - Anyone who is enrolled in Parts A, B, or C is eligible for the prescription drug
coverage
- Monthly premium is based off income
Source: SocialSecurity.gov Medicare
PAGE 12
ENROLLMENT PROCESS
PAGE 13
ENROLLMENT PROCESS: APPLICANT
• Applicants can enroll in an Exchange through the Exchange
website, in person at a designated assistance center, via toll-free
telephone number, or by mail
• The following information will be needed when completing an
Exchange application:
o Name
o Address
o Date of birth
o SSN
o Proof of U.S. citizenship/immigration status
PAGE 14
ENROLLMENT PROCESS: APPLICANT
• Notifications of eligibility are sent out once the determination is
complete
• Notifications letters should explain
o the applicant’s eligibility determination
o the steps taken and any remaining steps needed to complete
enrollment process
o the appeal process available to the applicant
PAGE 15
ENROLLMENT PROCESS: APPLICANT
• Through enrollment process, if applicant is found eligible for
government-based healthcare (e.g., Medicare, CHIP, or
Medicaid) the Exchange will automatically enroll applicant into
program
• Applicants can shop through Exchange to find the best coverage
option for their situation
• The Exchange will provide notification to the chosen insurance
issuer
PAGE 16
ENROLLMENT PROCESS: EMPLOYER
• Employers can submit an application to the Small Business
Health Options Program (SHOP) Exchanges to determine
eligibility*
• Once employer’s application is approved, the SHOP will help the
employer both enroll and select health plan options for their
employees
PAGE 17
*UPDATES TO SHOP PROGRAM
• The requirement that a SHOP must allow employers the option to
offer employees a choice among all qualified health plans (QHPs) at
the metal level (i.e., bronze, silver, gold, or platinum) chosen by the
employer has been delayed for one year.
• For plan years beginning before January 1, 2015 federally facilitated-
SHOPs will not offer an employee-choice option but will instead allow
employers to offer their employees a single QHP from the SHOP's
available choices. State-operated SHOPs may, but are not required to,
offer an employee-choice option.
• SHOP special enrollment period has been changed from 60 days to 30
days after a qualifying event.
• HHS has posted an application for SHOP eligibility for employers that
are not able to apply online or are not working with a broker and an
application for employees to submit to check their eligibility for SHOP
coverage from their employer.
As of
6/2013,
HHS has
issued final
regulations
around the
SHOP
program
PAGE 18
ENROLLMENT PROCESS:
EMPLOYER/SHOP
• The SHOP will provide notification to:
o employers regarding eligibility to participate in the Exchange
o employees regarding the plan options and how to enroll
o the insurer containing the employees’ enrollment information
• The SHOP is also required to notify HHS that the employer is
providing insurance and the eligible employees have enrolled in
a QHP
PAGE 19
ENROLLMENT VERIFICATION
PAGE 20
ENROLLMENT VERIFICATION:
APPLICANT
• U.S. citizenship and incarceration status will be verified by:
o Comparing records at the Social Security Administration
o If the information cannot be confirmed, HHS will go to the
Department of Homeland Security for confirmation
• Other application criteria will be verified against the respective
federal agencies
PAGE 21
ENROLLMENT VERIFICATION:
APPLICANT
• HHS will conduct annual redeterminations to determine
eligibility for upcoming plan year
o If applicants are approved, they will receive notification showing
data used to make the decision and their eligibility status
o If applicants are not approved, they will receive coverage for one
month after notification and can no longer claim tax benefits
• Applicants will need to supply any information that has changed
• Applicants will need to sign and return the notification
• After the signed notification is received, applicants can re-
enroll/terminate/change health plans
PAGE 22
ENROLLMENT VERIFICATION:
EMPLOYER
• To verify employer submitted information, the SHOP will cross
reference the employer’s information with government agencies
• The SHOP will redetermine employer eligibility through review
of the annual report submitted to it by the employer
PAGE 23
PENALTIES
PAGE 24
PENALTIES:
INDIVIDUALS AND EMPLOYERS
Individuals
• Penalties will be imposed for failure to maintain the
minimum level of individual coverage
o Penalties will either be a flat rate or a percentage of income,
whichever is higher
o Penalty rates will be adjusted annually
o IRS will administer and collect the penalty
Employers (50+ employees)
• If coverage is inadequate or not provided, a penalty will be
assessed based on the annual applicable dollar amount and
number of full-time employees
PAGE 25
APPEAL PROCESS
PAGE 26
APPEAL PROCESS: APPLICANT
• Each state will be responsible for creating their own appeal
process
• The Exchange will notify applicants if they are ineligible for
government-based healthcare and provide alternative options
for affordable healthcare
• Applicants can appeal adverse eligibility decisions and cost
reimbursement denials from insurance companies through an
internal or external appeal process
PAGE 27
APPEAL PROCESS: EMPLOYER
• An employer will be able to appeal an adverse eligibility
determination made by a SHOP
• The SHOP must give the employer 30 days notice to respond to
an eligibility denial and submit the necessary documentation to
the SHOP
• If the SHOP still denies eligibility after receiving documentation
from the employer, the employer may request an external
appeal review by a third party arbitrator
PAGE 28
KEY DATES
PAGE 29
KEY DATES: EXCHANGE ENROLLMENT
DATE EVENT
January 1, 2013 For 2012 tax year, employers need to include on the employee’s W-2
the cost of employer-sponsored health coverage.
o They must include both employer and employee portions of the cost
of health benefits.
The tax deduction will be eliminated for employers who receive
Medicare Part D retiree drug subsidy payments.
o These payments are a federal subsidy paid to employers who offer
retirement benefits for prescription drugs.
o Employers who receive this payment will have to include the amount
as taxable income.
March 1, 2013 • Employers must provide all employees with a written notice detailing:
- the availability of the healthcare Exchange,
- a description of the services provided,
- contact information for assistance,
- possible tax credit eligibility, and
- information regarding loss of employer sponsored coverage if they
purchase individual coverage in a QHP through the Exchange.
PAGE 30
KEY DATES: EXCHANGE ENROLLMENT
DATE EVENT
October 1, 2013 • Open enrollment period begins for the Exchanges
January 1, 2014 ACA Exchanges are in effect
Any U.S. citizen/legal resident who does not have health insurance and
is not exempt will be liable for a tax penalty
Employers that do not provide health insurance coverage will be fined
PAGE 31
REED & ASSOCIATES, CPAS
For more information on Reed & Associates, CPAs please
contact us at:
inquire@reedassociatescpas.com
Phone: 860-395-1996
Or visit our website:
reedassociatescpas.com
Quality. Integrity. Experience.

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The Affordable Care Act Part 2: Eligibility and Enrollment

  • 1. THE AFFORDABLE CARE ACT: ELIGIBILITY & ENROLLMENT
  • 2. PAGE 2 OVERVIEW • Eligibility Requirements • Exchange Enrollment • Eligibility & Enrollment Verification • Penalties • Appeal Process • Key Dates
  • 4. PAGE 4 ELIGIBILITY: REQUIREMENTS • For an individual to qualify for the Exchange they need to: o Be a U.S. citizen, national, or legal resident o Must reside in the same state that they are applying for coverage o For programs that require an income eligibility, income will be based off Modified Adjusted Gross Income • An individual is not eligible for coverage through the Exchange if incarcerated, unless charges are pending • For CHIP, Medicaid, and Medicare, individual must meet that program’s specific eligibility requirements
  • 5. PAGE 5 ELIGIBILITY: EXEMPTIONS • Individuals must have the minimum level of healthcare coverage provided or face a penalty • The following categories provide exemptions for individuals from this coverage requirement: o Religious Exemptions o Undocumented Immigrants o American Indians o Financial Hardships o Incarceration
  • 6. PAGE 6 ELIGIBILITY: PROHIBITED FACTORS • Issuers can no longer deny coverage to individuals with pre-existing conditions • Issuers are no longer able to drop individuals due to the diagnosis of serious illnesses • Issuers are no longer allowed to set annual and/or lifetime limits
  • 7. PAGE 7 ELIGIBILITY: GOVERNMENT BASED HEALTHCARE Medicaid • A state-based healthcare program that provides coverage to low- income households and individuals with disabilities CHIP • CHIP is the Children’s Health Insurance Program Medicare • A government health insurance program administered by the Centers for Medicare and Medicaid Services
  • 8. PAGE 8 ELIGIBILITY: MEDICAID Medicaid Eligibility Before ACA Medicaid Eligibility After ACA - Pregnant women and children (<6 years) whose family income is ≤ 133% of the Federal Poverty Level - Children under 19 whose families are at or below the FPL - Families with children that meet the Aid to Families with Dependent Children - Most Supplemental Security Income recipients - Recipients of adoption or foster care individuals - Special protected groups - Certain Medicare beneficiaries - Certain optional groups Source: CMS.gov - Brief Summaries of Medicare and Medicaid and Kaiser Family - Medicaid A Primer - Eligibility groups streamlined to - children - pregnant women - parents and caretaker relatives - adults (ages 19-64) - Income eligibility will be based off modified adjusted gross income and household income - Eligibility based off monthly income at time of application - Minimum income eligibility for adults is 133% of FPL Source: Federal Register - Medicaid Program Eligibility Changes under the ACA and Kaiser Family - Medicaid and the uninsured
  • 9. PAGE 9 ELIGIBILITY: CHIP • CHIP covers children whose family income is too high for Medicaid • The ACA will keep the same eligibility standards in place through 2019 • The ACA has expanded eligibility beyond the original requirements of children under 19 and household incomes of 200%
  • 10. PAGE 10 ELIGIBILITY: MEDICARE • Overall eligibility for Medicare does not change with the enactment of the ACA • Medicare eligibility requirements include: o Being a U.S. citizen or legal immigrant o Being age 65 or older Source: SocialSecurity.gov Medicare and Proof of Citizenship
  • 11. PAGE 11 ELIGIBILITY: MEDICARE Medicare Part Eligibility Requirements Part A Individual is eligible if under age 65 and: - Receives Social Security Disability Insurance for minimum of 24 months, - Receives disability from Railroad Retirement Board, - Receives disability due to Lou Gehrig’s disease, - Has worked 10 years in a governmental job where Medicare taxes were paid and meet requirements for Social Security Disability; or be the child/widower of someone who has met those requirements, or - Has permanent kidney failure or has received a kidney transplant Individual is eligible if age 65 or older and: - Receives benefits from Social Security or Railroad Retirement, - Has an eligible spouse, - Has worked (either individual or spouse) in a government job where Medicare taxes were paid, or - A dependent parent of a fully insured deceased child Part B - Anyone eligible for Part A can enroll in Part B - Monthly premium is based off income Part C - Anyone who is eligible for Parts A and B can enroll in Part C Part D - Anyone who is enrolled in Parts A, B, or C is eligible for the prescription drug coverage - Monthly premium is based off income Source: SocialSecurity.gov Medicare
  • 13. PAGE 13 ENROLLMENT PROCESS: APPLICANT • Applicants can enroll in an Exchange through the Exchange website, in person at a designated assistance center, via toll-free telephone number, or by mail • The following information will be needed when completing an Exchange application: o Name o Address o Date of birth o SSN o Proof of U.S. citizenship/immigration status
  • 14. PAGE 14 ENROLLMENT PROCESS: APPLICANT • Notifications of eligibility are sent out once the determination is complete • Notifications letters should explain o the applicant’s eligibility determination o the steps taken and any remaining steps needed to complete enrollment process o the appeal process available to the applicant
  • 15. PAGE 15 ENROLLMENT PROCESS: APPLICANT • Through enrollment process, if applicant is found eligible for government-based healthcare (e.g., Medicare, CHIP, or Medicaid) the Exchange will automatically enroll applicant into program • Applicants can shop through Exchange to find the best coverage option for their situation • The Exchange will provide notification to the chosen insurance issuer
  • 16. PAGE 16 ENROLLMENT PROCESS: EMPLOYER • Employers can submit an application to the Small Business Health Options Program (SHOP) Exchanges to determine eligibility* • Once employer’s application is approved, the SHOP will help the employer both enroll and select health plan options for their employees
  • 17. PAGE 17 *UPDATES TO SHOP PROGRAM • The requirement that a SHOP must allow employers the option to offer employees a choice among all qualified health plans (QHPs) at the metal level (i.e., bronze, silver, gold, or platinum) chosen by the employer has been delayed for one year. • For plan years beginning before January 1, 2015 federally facilitated- SHOPs will not offer an employee-choice option but will instead allow employers to offer their employees a single QHP from the SHOP's available choices. State-operated SHOPs may, but are not required to, offer an employee-choice option. • SHOP special enrollment period has been changed from 60 days to 30 days after a qualifying event. • HHS has posted an application for SHOP eligibility for employers that are not able to apply online or are not working with a broker and an application for employees to submit to check their eligibility for SHOP coverage from their employer. As of 6/2013, HHS has issued final regulations around the SHOP program
  • 18. PAGE 18 ENROLLMENT PROCESS: EMPLOYER/SHOP • The SHOP will provide notification to: o employers regarding eligibility to participate in the Exchange o employees regarding the plan options and how to enroll o the insurer containing the employees’ enrollment information • The SHOP is also required to notify HHS that the employer is providing insurance and the eligible employees have enrolled in a QHP
  • 20. PAGE 20 ENROLLMENT VERIFICATION: APPLICANT • U.S. citizenship and incarceration status will be verified by: o Comparing records at the Social Security Administration o If the information cannot be confirmed, HHS will go to the Department of Homeland Security for confirmation • Other application criteria will be verified against the respective federal agencies
  • 21. PAGE 21 ENROLLMENT VERIFICATION: APPLICANT • HHS will conduct annual redeterminations to determine eligibility for upcoming plan year o If applicants are approved, they will receive notification showing data used to make the decision and their eligibility status o If applicants are not approved, they will receive coverage for one month after notification and can no longer claim tax benefits • Applicants will need to supply any information that has changed • Applicants will need to sign and return the notification • After the signed notification is received, applicants can re- enroll/terminate/change health plans
  • 22. PAGE 22 ENROLLMENT VERIFICATION: EMPLOYER • To verify employer submitted information, the SHOP will cross reference the employer’s information with government agencies • The SHOP will redetermine employer eligibility through review of the annual report submitted to it by the employer
  • 24. PAGE 24 PENALTIES: INDIVIDUALS AND EMPLOYERS Individuals • Penalties will be imposed for failure to maintain the minimum level of individual coverage o Penalties will either be a flat rate or a percentage of income, whichever is higher o Penalty rates will be adjusted annually o IRS will administer and collect the penalty Employers (50+ employees) • If coverage is inadequate or not provided, a penalty will be assessed based on the annual applicable dollar amount and number of full-time employees
  • 26. PAGE 26 APPEAL PROCESS: APPLICANT • Each state will be responsible for creating their own appeal process • The Exchange will notify applicants if they are ineligible for government-based healthcare and provide alternative options for affordable healthcare • Applicants can appeal adverse eligibility decisions and cost reimbursement denials from insurance companies through an internal or external appeal process
  • 27. PAGE 27 APPEAL PROCESS: EMPLOYER • An employer will be able to appeal an adverse eligibility determination made by a SHOP • The SHOP must give the employer 30 days notice to respond to an eligibility denial and submit the necessary documentation to the SHOP • If the SHOP still denies eligibility after receiving documentation from the employer, the employer may request an external appeal review by a third party arbitrator
  • 29. PAGE 29 KEY DATES: EXCHANGE ENROLLMENT DATE EVENT January 1, 2013 For 2012 tax year, employers need to include on the employee’s W-2 the cost of employer-sponsored health coverage. o They must include both employer and employee portions of the cost of health benefits. The tax deduction will be eliminated for employers who receive Medicare Part D retiree drug subsidy payments. o These payments are a federal subsidy paid to employers who offer retirement benefits for prescription drugs. o Employers who receive this payment will have to include the amount as taxable income. March 1, 2013 • Employers must provide all employees with a written notice detailing: - the availability of the healthcare Exchange, - a description of the services provided, - contact information for assistance, - possible tax credit eligibility, and - information regarding loss of employer sponsored coverage if they purchase individual coverage in a QHP through the Exchange.
  • 30. PAGE 30 KEY DATES: EXCHANGE ENROLLMENT DATE EVENT October 1, 2013 • Open enrollment period begins for the Exchanges January 1, 2014 ACA Exchanges are in effect Any U.S. citizen/legal resident who does not have health insurance and is not exempt will be liable for a tax penalty Employers that do not provide health insurance coverage will be fined
  • 31. PAGE 31 REED & ASSOCIATES, CPAS For more information on Reed & Associates, CPAs please contact us at: inquire@reedassociatescpas.com Phone: 860-395-1996 Or visit our website: reedassociatescpas.com Quality. Integrity. Experience.

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