New SEP Verification Requirements Could Further Deter Enrollment

New special enrollment period (SEP) verification processes recently implemented by CMS in response to insurer concerns about high SEP-enrollee costs may deter SEP enrollment, particularly by healthy individuals, according to areport from the Urban Institute. Until this year, applicants were only required to attest to their SEP eligibility. Moving forward, applicants must submit documentation with their application for verification purposes. On average, 33.5 million individuals lose coverage each year outside of an open enrollment period for reasons that qualify for a SEP, but, according to research cited in the report, only 5% of SEP-eligible consumers enrolled through an SEP in 2015. The authors argue that low SEP utilization rates contribute to high SEP enrollee costs and that instituting barriers to SEP enrollment will further encourage only less healthy individuals to comply with application requirements. The authors recommend replacing CMS' documentation-based process with a data-based, electronic verification system that only requires documentation if electronic verification fails. The authors further note that loss of minimum essential coverage accounts for 94% of SEP eligibility and that such losses can be verified through data-matching with a consumer's previous insurer.