Feds announce change to 2016 Open Enrollment dates

Originally slated to begin Oct. 1, 2015 and end Dec. 15, 2015, new CMS guidance indicates that the next Open Enrollment will instead start on Nov. 1, 2015 and end on Jan. 31, 2016.

CMS released on Feb. 20 its Final Notice of Benefit and Payment Parameters for 2016. A significant point of interest is a one-month shift in dates for the third Open Enrollment period.

The change in dates is concurrent with the Washington Health Benefit Exchange (WAHBE) finalizing its timeline to transfer payment functions to carriers and proposed state legislation mandating this happen before open enrollment begins.

WAHBE and carrier impact

Open enrollment dates are of particular importance to the WAHBE as it works through its timelines for removing premium aggregation for the upcoming plan year.

In a December 2014 Board meeting, the WAHBE voted to eliminate billing and payment features, or premium aggregation, from their website, transferring this responsibility directly to insurance carriers.

The timeline for this transfer of responsibility is yet undecided. However, new legislation may be pushing the deadline. House Bill 1628 and its companion Senate Bill 5142 would prohibit the Exchange from aggregating premiums effective the beginning of 2016 open enrollment period.
The modified open enrollment dates and the passing of this legislation are both impacts that the Exchange must now factor into its timelines.
While the CMS news release does not indicate a specific reason for the shift in dates, it does give detailed clarification for carriers on topics such as prescription drug requirements and cost-sharing restrictions.
Carriers may also experience changes to their filing dates. The Office of the Insurance Commissioner (OIC) announced an April 3, 2015 deadline for all Qualified Health Plans in anticipation of an Oct. 1 open enrollment date. However, it is yet unknown whether the OIC will adjust these deadlines with the CMS announcement.
Consumer impact
For consumers, this date change means a similar enrollment timeframe as the last open enrollment which ran from Nov. 15 to Feb. 15. Namely, consumers will once again be shopping for health plans over the holiday season with opportunities to enroll into the 2016 year.
At the close of 2014, the WAHBE hinted at sluggish enrollment figures during the holiday, with only about 10,000 new enrollments as of their Dec. 11 report. WAHBE hoped for, and did eventually see, a surge in enrollments after the New Year. As the second Open Enrollment drew to a close, the number of new enrollees rose to 66,420, with nearly 160,000 total individual marketplace enrollees.
State of Reform will update with announcements from WAHBE and OIC responding to the CMS guidance.