Now that the open enrollment period has closed completely, it’s time to discuss the circumstances of individuals that will come up during the year that will affect their eligibility for special enrollment periods (SEPs). One of the more unique situations that can occur is referred to as “churning.” This is when an individual’s income fluctuates and they go between Medicaid eligibility and eligibility for coverage through the Marketplace (in states that have expanded Medicaid). In states where they have not expanded Medicaid (and assuming the individual doesn’t meet some other Medicaid eligibility criteria), then the individual would churn between not being eligible for the Premium Tax Credit to being eligible, thereby making enrolling in a plan much more financially feasible. This of course is due to the fact that the Premium Tax Credit was written into the tax code when it was assumed that everyone under 100% of the Federal Poverty Level (FPL) would be covered under the Medicaid expansion. Therefore, the Premium Tax Credit is not available for individuals under 100% of FPL.
The policy implications for churning are significant as going between Medicaid and private coverage may result in a lack of continuity of care if the individual is required to change providers as a result of the change in coverage. However, what does this mean for navigators and enrollment specialists? It means that even though open enrollment is over, there may be lower income workers who become newly eligible for coverage through the marketplace as a result of their change in income. This becomes an educational opportunity for navigators and enrollment specialists. The Center for Healthcare Strategies, Inc. said it best in their issue brief on churning when they wrote: “Because changes in eligibility will result in coverage shifts, consumer education will be a critical element of a churn mitigation strategy to ensure that individuals remain enrolled in a health coverage option. Navigators or assisters should be at-the-ready to help consumers who are experiencing income and/or life changes enroll in, and understand the details of, another coverage option. Navigators can seek information during the initial enrollment period about future anticipated changes in income or circumstances to help consumers minimize coverage gaps.”
Navigators should make sure they understand churning so that they will be able to identify when a consumer could potentially be impacted by this phenomenon. To learn more about churning, check out these resources:
- Kaiser Health News Article
- Center for Healthcare Strategies Issue Brief
- UC Berkeley Center for Labor Research and Education Policy Brief on Churning in California
- Health Matrix Article “Crossing 138: Two Approaches to Churn under the Affordable Care Act”
- Health Affairs Article “Medicaid and Marketplace Eligibility Changes Will Occur Often in All States; Policy Options Can Ease Impact”