CMS confirms the disenrollment of approximately 1.5 million “improper” ACA enrollments so far this year, and estimates there are another 4 million left to address. CMS is sending electronic files to each ACA carrier listing the carrier’s ACA clients CMS believes are improper enrollments.
Each carrier has to go through these files and address each client’s issues directly with CMS to change their assessment, producing any documentation that addresses the “improper” enrollment determination. It’s important to note that all of this data is based on how CMS currently characterizes the data.
One national ACA carrier says it received its CMS file of these “improper” ACA enrollments, which numbers close to 300,000 of its ACA members. The company’s CEO says they’re actively reviewing their file and finding “a number of cases where we’ve actually had contact with people. So [CMS’] list was based on a set of assumptions that they went through on the file. The actual result will depend on our ability to go through those files.”
Each ACA carrier has a chance to address these files as their internal capabilities allow, so the CMS estimate will be a lower number of disenrollments in reality after this process ends. The challenge will be conducting these reviews as many carrier resources prepare for the execution of the 2027 OEP.
Next Steps for ACA Agents
All ACA agents with clients on a monthly premium subsidy or cost-sharing reduction should review the documents for these clients to ensure everything the client needs to qualify for these items is submitted to the ACA carrier. If you find ACA clients with missing documentation for one or both of these items, please contact your client immediately to determine if they may provide the missing documentation to you or the ACA carrier as quickly as possible.
And if you have ACA clients that are now former ACA clients, you’ve hopefully already communicated with them about the possible alternatives available to provide them financial protection from healthcare expenses. Additional options in catastrophic and ACA-alternative policies are additional protection products for these former ACA clients to consider.
If you haven’t yet heard from an ACA carrier partner regarding this process, please reach out to them to clarify where your ACA partner company is in this process with CMS and how you may assist them. Proactive outreach and review now will result in less work later, closer to or during OEP.
Agility will share more updates on this CMS process as we receive them.
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