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Paper applications threaten family health insurance coverage

Will I have health insurance if I filed a paper applications?

Covered California had high expectations for 21st century e-commerce technology but agents and consumers have resort to 19th century pen and paper. There has been an avalanche of paper applications into Covered California significantly slowing down the verification and enrollment process. The sluggish processing of applications means that some families may not have insurance coverage on January 1, 2014 as promised. See “Thousands of applications stalled at Covered California

Consumers spooked into paper applications

The initial website problems at Healthcare.gov and Covered California spooked many consumers from applying online and took the option, offered by Covered California, to send in a paper application. Certified Insurance agents were in a similar or worse position as the agent side of Covered California enrollment system only started functioning in late November. Consequently, there are agents that literally wrote all their client’s health insurance applications on paper and mailed or faxed them Covered California. Additionally, some agents thought ALL business had to go through Covered California, submitting applications that don’t qualify for premium assistance and shouldn’t go through the state exchange.

Covered California pushes paper back to agents

This mountain of paper is evidently strangling Covered California operations. Certified Agents received a perky little email from the state exchange informing them they would have to complete or re-enter all paper applications they have submitted through the CalHEERS website. Essentially what Covered California is doing is pushing the data entry work back to the agents who file the application in the first. Also placed at the agent’s feet is the uploading of verification documents for each client. There was no word if Covered California was forcing Certified Enrollment Counselors to also review and complete submitted paper applications.

Dear Agent letter from Covered California

Dear Certified Agents:

I’m sure you share our excitement over the volume of consumer interest in California to sign up for affordable health care coverage through Covered California. This positive interest, however, has presented us with its own challenges. Helping consumers finalize the enrollment process is our key goal, and Covered California has developed a number of strategies to ultimately serve our consumers. As a Covered California Certified Insurance Agent, we’re impressed with your ability to reach and enroll consumers, as well as partner with us to resolve those challenges.

As we informed you last week, our challenge now is to process those paper applications. We have added additional resources and implemented many solutions to streamline the process of data entry. In addition, your assistance is needed to complete applications generated by your customers so we can ensure timely coverage.

The buck doesn’t stop on the Covered California desk

The staff at Covered California is sending a client designation request to the agents that submitted and signed the original paper application. It is then the responsibility of the agent to move the application to the eligibility stage within CalHEERS. This seems like a massive “hand washing” of responsibility on the part of Covered California. If an application designated to an agent isn’t completed and no conditional coverage issued from the exchange, Covered California will point to the agent as not fulfilling his or her role.

Back room deal

Unconfirmed reports from individuals connected with Covered California state that all the mailed and fax applications sent into the exchange have been languishing in a back room. Further information states that the Temp Agency hired by Covered California for data entry of the paper applications doesn’t even offer health insurance to the temporary workers. Either way, there are thousands of applications that need to be keyed into the CalHEERS system before the agent who originally sent in the application will be able to verify and submit it for approval.  Now, will agents even be compensated for this…See Agent Alert: Covered California drops health application data.

Dana Howard clueless on how insurance works

Dana Howard, spokesperson for Covered California, responded to the inquiries from a local TV station about the idle paper applications-

Dana Howard, a spokesman for Covered California, told KCRA 3 Monday that there is no backlog of applications to process, in spite of what insurance agents said the health agency told them.

According to Howard, insurance agents are responsible for making sure their clients are properly enrolled, even if it means submitting information twice.

“It’s repetitive, but it’s worth it,” said Howard. “We’re talking about people who did not have health insurance until now.”

Howard said agents were always meant to do some of the data input on behalf of their clients, but couldn’t because the website’s portal for insurance agents wasn’t ready until two weeks ago.

“The agents have been compensated by insurance companies to make sure that their clients get enrolled properly,” said Howard.

Mr. Howard, there is no compensation from insurance companies for an agent enrolling an individual or family in Covered California that is deemed eligible for Medi-Cal. Paper applications for Medicare Advantage plans placed on behalf of Medicare beneficiaries with and insurance company are automatically enter by the insurance company whether the enrollment comes through mail or fax. I agree with Mr. Howard that agents are responsible for the clients enrollment. But…

Covered California misrepresented the systems functionality

Covered California has misrepresented the process to Certified Agents and Certified Enrollment counselors. Even the CalHEERS enrollment system that agents use is flawed and routinely issues error messages when attempting to change an application or upload documents. Mr. Howard needs to spend some time walking in the shoes of the agents and that of the staff at Covered California and then maybe he’ll understand the challenges and hurdles put before the agent community in California.

Covered California explains process to agents

Applications In Process: As the applications are processed by Covered California, agent delegations are being updated.  First and foremost, please remember to check your online portal several times a day for new delegations. Agents must accept the delegation in order for the agent to move the application forward. Once you accept the delegation, you will need to review applications for completeness, take the appropriate steps to obtain any required information, and complete any missing information using a copy of the paper application that you submitted.   If you do not have a copy of the paper application, contact your client to gather the remaining information. This will ensure that your client’s application is submitted and coverage is effectuated. 

Will agents receive compensation?

To rub a little salt in a widening wound, anecdotally, I am finding that none of my agent designations are being transferred to the insurance carriers. That designation from the client creates the “Broker of Record” whereby the agent earns a commission. No Broker of Record, no commission, which means we are working for free.

Will families have health insurance in 2014?

Whether the application was paper, online, or through an agent, the incredibly slow process of verifying eligibility for premium assistance has many families wondering if they will have coverage at the first of the New Year when their old plans are closed. Six weeks after one of my clients enrolled online they just received a letter on December 8th from Covered California requesting additional documentation.

Arduous process of verification and uploading

From a conversation with a Covered California staff member, if the household application is approved eligible for premium assistance before the end of 2013, they will have coverage in 2014. As I have been able to learn from from the different parties involved in the transactions the process goes something like this

No billing until after the first of the year

It is possible that an applicant may not receive an invoice for the first month’s premium until after the first of January. If they had been deemed eligible for assistance and they make the premium payment, Covered California assured me that the health insurance would be retroactive to the first of the month.

Covered California model contract with health plans

3.21 Enrollment: Commencement of Coverage.

(a) Individual Exchange: The provisions of this Section 3.21(a) shall apply with respect to the Individual Exchange.

(i) The Exchange shall (i) notify Contractor regarding each eligible applicant who has completed an application for enrollment and designated Contractor as the Certified QHP, and (ii) transmit information required for Contractor to enroll the applicant within five (5) business days of verification of eligibility and selection of Contractor’s QHP. Contractor shall ensure a coverage effective date for the Enrollee as of (1) the first day of the next subsequent month for a QHP selection notice received by the Exchange between the first day and fifteenth (15) day of the month, or (2) the first day of the second following month for QHP selections received by the Exchange from the sixteenth day through the last day of a month, or (3) such other applicable dates specified in 45 C.F.R. 155. § 410 for the Open Enrollment Period and 45 C.F.R. § 155.420 for the Special Enrollment Period and/or as otherwise established by Contractor in accordance with applicable laws, rules and regulations. The Exchange shall require payment of one hundred percent (100%) of the entire first month premium to be received by the Exchange on or before the fourth (4th) remaining business day of the month in order to commence coverage as of the first (1st) day of the following month.

90 Day Letters

No one at Covered California has explained the 90 letter to agents or consumers. From reading one of the 90 Day Letters received by a client, it sounds like Covered California is giving conditional approval to receive premium assistance for 90 days while the individual or family sends or uploads the requested documents. In the case of my client, Covered California was requesting a copy of everyone’s social security card because they couldn’t match them online. This would be a comical situation if this All-American white bread family wasn’t experiencing an acutely high level of anxiety of over the whole process.

Nothing spells delay like confusion

Covered California is partly to blame for creating their mountain of stalled applications. They gave little training to agents on the necessary documents to file with applications and some of the questions on the applications were as clear as mud. The most misunderstood question was “Are you a naturalized citizen?” Covered California finally changed the text on the online application to clarify that a naturalized citizen is a person who was not born in the U.S. and became a citizen through the naturalization process.  How many applications are stalled because someone filled in they were naturalized but were really born in the U.S.?

Medi-Cal residency

Another issue has been qualifying for Medi-Cal. All Medi-Cal applications must be accompanied by residency verification. Medi-Cal is administered at the county level and they will need to see proof of residence such as car registration or utility bill. There are also computer system integration challenges that Medi-Cal can’t address until after the first of the year. It doesn’t sound like many of  applications in late December for Medi-Cal will be fully implemented until after the first of the year. On the upside, Medi-Cal is retroactive 90 days from approval so any health care expenses occuring after the first of the year should be covered. See “Medi-Cal Verification

Telephone wait times increase exponentially

As the month of December wears on the hold or wait time at both Covered California and the insurance companies is lengthening. If I call Covered California and am under the 200th person waiting for assitance, I feel fortunate because my wait will only be about 90 minutes. The usually good customer service of many of the insurance companies has also been degraded as prospective members try to determine if their physicians are really in-network. Most of the doctors have no clue, but that is another blog post. It is with extreme embarrassment that I can hum the “hold music” for Covered California and all the carriers in my sleep.

Go direct to the insurance company

If you went through an agent and he or she placed a paper application with Covered California for your health insurance, give the agent a call to see where your application is in the process. You should be prepared to make copies of any supporting documents and get them to the agent for uploading. I have been asking folks just to take a picture of the document with their smart phones and send it to me. Finally, if you don’t need or don’t qualify for premium assistance through Covered California, ditch the application and go straight to the insurance company or health plan of your choice.

Online application

I never used paper applications unless I was helping out at a public enrollment event. With the updated agent portal I’ve been entering all applications online without ever having to sit down with the client. I have been sending families a modified Covered California paper application in PDF format. They fill it out and email it back to me and then I create the account directly at Covered California on their behalf. So far it has been a good system.

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Full text of Covered California correspondence with agents

Dear Certified Agents:

I’m sure you share our excitement over the volume of consumer interest in California to sign up for affordable health care coverage through Covered California. This positive interest, however, has presented us with its own challenges. Helping consumers finalize the enrollment process is our key goal, and Covered California has developed a number of strategies to ultimately serve our consumers. As a Covered California Certified Insurance Agent, we’re impressed with your ability to reach and enroll consumers, as well as partner with us to resolve those challenges.

As we informed you last week, our challenge now is to process those paper applications. We have added additional resources and implemented many solutions to streamline the process of data entry. In addition, your assistance is needed to complete applications generated by your customers so we can ensure timely coverage.   The following outlines your role in finalizing these important applications.

Applications In Process: As the applications are processed by Covered California, agent delegations are being updated.  First and foremost, please remember to check your online portal several times a day for new delegations. Agents must accept the delegation in order for the agent to move the application forward. Once you accept the delegation, you will need to review applications for completeness, take the appropriate steps to obtain any required information, and complete any missing information using a copy of the paper application that you submitted.   If you do not have a copy of the paper application, contact your client to gather the remaining information. This will ensure that your client’s application is submitted and coverage is effectuated.

Non-Delegated Applications: If you have submitted paper applications but the delegations do not appear in your online portal, Covered California suggests you enter in the application yourself, as an option, to expedite processing.  Our service team will confirm that your client’s information has not already been submitted before entering data to reduce the number of duplicate applications.

In either case, please be mindful that there are certain areas of the application that need special attention.

These areas are as follows:

1. Sequence of Information – The online and paper applications do not necessarily flow in the same sequence.  Therefore, to complete the online application, you may need to find certain information on different pages of the paper application.

2. Applying for Financial Assistance – Consumers may request financial assistance (a.k.a., subsidy) to help pay for their health insurance or opt for no financial assistance.

If the paper application is for:

• Financial Assistance – The application will be 34 pages.  For these applications, you must answer “Yes” to the first question on the Apply for Benefits screen regarding the consumer’s desire to request financial assistance for their health insurance.

• Non-Financial Assistance – The application will be 6 pages.  For these applications, you must answer “No” to the first question on the Apply for Benefits screen regarding the consumer’s desire to request financial assistance for their health insurance.

3. Personal Tax Information – More information is requested on the “Personal Data – Tax Information” screen than is collected on the paper application.  When you get to the Tax Information screen, you will need to call the consumer to obtain the mandatory information to continue processing their application.

4. Tax Filing Status – To be eligible for APTC, married consumers must plan to file as “Married Filing Jointly” in the upcoming tax year.  If they plan to file under any other status (i.e., Married Filing Separately or Head of Household), then they will not be eligible for APTC.

However, there is an exception when married couples who are not legally divorced live apart in separate households for more than 6 months during a taxable year and one or both spouses are allowed to file a tax return as head of household (HOH) due to supporting a dependent child(ren) living in the same household as the spouse claiming the child.   In that case, the spouse filing as HOH can be eligible for APTC.

5. California Residency – While all programs require validation of a consumer’s identity to complete the application process, proof of California residency is only required if a consumer is determined eligible for MAGI Medi-Cal.

6. US Citizen Versus Naturalized Citizen – When completing the online application, it is important that you check either US Citizen or Naturalized Citizen but not both.

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