Trying to "true up" some of the issues and make enrollment opportunities more even, the COBRA Qualifier deadline to enroll was extended to 60 days ... the same as it has been for COBRA all along. This is a significant change because it is the first movement from the HIPAA event deadline of 30 days when coverage is lost for reason other than non-payment of premium or fraud. This just makes sense. But why did it take so long? You know the answer to that ...
There are some other proposed changes too. The language in the COBRA General Notice (New Hire Letter) and the COBRA Election Notice (Qualifying Event Letter) are going to be updated to place more emphasis on the Marketplace plans and judging from some of the phrases used ... make COBRA less palatable.
An article appeared just yesterday in a health insurance broker trade online magazine that said COBRA premiums are typically 10 times higher than Marketplace plans ... Really? What country is that again?
COBRA premiums do seem high because they are 102% of the invoiced premium and sometimes that might be a low multiple ... like 2 or even 3 but 10? We don't think so. But, using composite rates and then getting pushed to an age-band of 64 or so could do a 5 multiple possibly.
Anyway. We are glad that some of these changes are occurring but it does reveal, more than ever that the PPACA did NOT get any input from folks like us that actually handle these things day in and day out. This was a simple change that should have been in PPACA release 1 and instead it is coming far too late and had NO communication requirement or template or even any encouragement for employers or administrators.
We are headed toward Open Enrollment all year round if many more extension and waivers are offered. There are significant reasons for an Open Enrollment deadline. The main reason is to guard against adverse selection, but that seems to be a foreign concept to HHS. Why should you worry about risk and exposure if balancing the checkbook or even worrying about how much money you have is a non-issue. It is looking less like insurance everyday. Heck, we have a color printer, maybe we should give it a try! Just kidding.