Update to Special Enrollment Period for Issuers Offering Individual Coverage

On March 29, 2021, the Department of Insurance and Financial Services (DIFS) issued Bulletin 2021-18 reminding issuers that DIFS will allow issuers offering ACA-compliant individual health coverage outside of the marketplace to participate in the Special Enrollment Period (SEP) to the same extent as issuers offering ACA-compliant individual coverage on the marketplace. This is not new guidance; rather, Bulletin 2021-18 supersedes Bulletin 2021-08 (previously reported on in the February 17, 2021, edition of Compliance Corner).

This information may continue to be of use to employees who have not been able to enroll in other coverage. As a reminder, this SEP for non-exchange coverage would likely not give rise to a qualifying event that would allow employees to terminate their employer group health plan coverage. It’s also important to note that these private health plans often meet ACA requirements, but consumers would not qualify for premium tax credits in order to help pay for them.

Bulletin 2021-18 »