Health Reform WK-EDGE Fountain of youth provided for aged stand-alone dental plans
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Friday, June 10, 2016

Fountain of youth provided for aged stand-alone dental plans

By Kathryn S. Beard, J.D.

Stand-alone dental plans (SADPs) offered on the federally-facilitated marketplace (FFM) will get assistance from CMS in effectuating coverage. CMS’ Center for Consumer Information and Insurance Oversight (CCIIO) announced its intention to auto-effectuate all remaining aged 2016 initial dental enrollment for policies without advance payments of the premium tax credit (APTC) to make sure that the agency accurately captures enrollment in SADPs and does not adversely affect consumers with APTCs (CCIIO Letter, June 1, 2016).

Aged initial policies are those with past coverage start dates that an issuer has neither effectuated nor canceled. CMS reviewed FFM enrollment data and determined that SADP issuers have higher rates of aged initial policies and also found that these issuers have lower success rates in submitting monthly enrollment reconciliation files. To ensure accurate enrollment, CMS will begin auto-effectuating all remaining initial SADP enrollments that are more than 90 days old. This auto-effectuating will begin before the September 2016 payment cycle and will not apply to dental policies with APTC to avoid adversely affecting consumers.

The CCIIO reminded issuers that to effectuate all active enrollments, they should submit complete and accurate monthly enrollment reconciliation files and should cancel any initial enrollments for which consumers have not paid their premiums before the September payment cycle. Issuers should cancel incorrectly effectuated dental enrollments using the existing inbound 834 and/or monthly reconciliation files submissions. For incorrectly effectuated dental enrollments, CMS will make payment adjustments to reverse any associated FFM user fees in the payment cycle following the issuer-submitted cancellation. The agency plans to work closely with issuers to improve the accuracy of its enrollment data records.

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