Your clients on non-grandfathered Humana Individual Major Medical plans (purchased between May 23, 2010 and July 31, 2013) will soon receive letters in the mail that will outline their options as 2014 healthcare reform changes approach.
In order to comply with the Affordable Care Act (ACA) regulations, Humana will be amending their current plans. However, they are also providing your clients with options. In general, your non-grandfathered clients will be presented with two choices:
- Option A – Stay on current plan for another year before moving to a 2014 ACA-compliant plan
Member keeps their current plan if they agree to a policy amendment. This will establish a policy plan year as Dec. 31, 2013, through Dec. 30, 2014. Humana will then amend their plan to be ACA compliant on Dec. 31, 2014.
It is very important to note that the member must take action to opt into this option within 30 days of receiving their letter. The amendment form they need to accept will be included with the letter.
Option B (Default) – Move to a 2014 ACA-compliant plan on Jan. 1, 2014
This is the default option if the member takes no action (does not opt into Option A). Option B will amend the member’s current plan to be ACA compliant on Jan. 1, 2014 with a rate increase at that time due to the added benefits they will receive.
Two Groups of Clients
Non-grandfathered members generally will be categorized into two groups based on their state and when they are scheduled for renewal.
Group 1 includes members who have already received their 2013 renewal rate increase in the states of:
- Arkansas, Arizona, Colorado, Florida, Indiana, Kansas, Kentucky, Michigan, Mississippi, North Carolina, Nevada, Ohio, Oklahoma, South Carolina, Virginia
If members in the above-listed states are scheduled for their renewals between the months of September and December, they will then fall into Group 2.
Group 2 includes all members in the states of:
- Alabama, Georgia, Illinois, Louisiana, Tennessee, Texas, Utah, Wisconsin and states listed in Group 1 with renewals scheduled between September and December
Group 2 members will receive their renewal rate increase on Dec. 1, 2013.
While there are several state-specific considerations that are described in the next section, the following two sample letters are a good general overview of what your clients will receive.
As mentioned above, there will be an amendment form for non-grandfathered members to sign if they select to opt-into Option A. Please note that for Illinois, Indiana, Kentucky and Ohio, Humana is waiting for DOI approvals of these amendment forms. If the DOI does not approve the filed amendments by Nov. 15, 2013, Humana will be unable to provide Option A and clients in these states will then automatically be provided with Option B.
Additional State-Specific Considerations
- When the member’s plan is amended to be ACA compliant, pediatric dental services are not included as required under the Federal Patient Protection and Affordable Care Act. This coverage is available in the insurance market and can be purchased as a stand-alone product.
- Member needs to contact Humana regardless if they select Option A or B, or their policy will be terminated on Dec. 31, 2013, and the member would need to purchase a new plan during the open enrollment period.
- If a member selects Option B, they will be mapped to a new ACA-compliant plan, as opposed to their current plan being made ACA compliant. Or, the member can select another ACA-compliant plan. Either way, the member must take action to contact Humana or their policy will be terminated.
- Some areas of the state will only be offered Option A, as Humana will not have an ACA- compliant plan available in those areas. This affects a very small amount of policies.
- If a member selects Option B, or does not take any action from their opt-in letter, they will be moved to an ACA-compliant plan, as opposed to their current plan being made ACA compliant. There will be no disruption to coverage during this transition.
- As mentioned earlier, please also note that for Kentucky, they are still waiting for DOI approval of the amendment form.
- In Missouri, Humana is required to terminate the member’s current plan on Dec. 31, 2013, and replace it with a new plan with 2014 ACA benefits beginning Jan. 1, 2014.
- Humana will not have an ACA-compliant plan available and will be terminating the member’s policy on Dec. 31, 2013. This impacts a very small amount of policies.
If you have any questions, please reach out to your GoHealth VMO Manager.