At Sterling Benefits, we are proactively working with multiple resources to dissect the various facets of the law and to understand the guidelines and timelines it presents to our clients. You can expect that we will provide ongoing communications and information as interpretation and implementation details continue to unfold from the government.

Our priority at Sterling Benefits is to stay focused on delivering value and quality customer service to our customers as we work together with health care reform. Significant changes will take place in 2014. In the meantime, there are some items that will require attention much sooner. We will keep you posted as details and clarifications from the government are made available. We encourage you to review this information and utilize our office as a resource in addressing questions and concerns.

Friday, April 4, 2014

Grace Period Provided for Payment of Premiums

Question: Must health plans participating in the exchanges provide individuals who purchase subsidized insurance coverage through the exchanges a 90-day grace period before terminating the coverage for non-payment of the premiums?

Answer: Yes. Under 45 CFR 156.270, individuals who purchase subsidized coverage through the exchanges must be provided a 90-day grace period before their coverage is cancelled for non-payment. The insurance plan is required to pay any claims incurred during the first 30 days of the grace period, but the insurance plan is not required to pay the claims incurred during the last 60 days of the grace period if the individual's coverage is terminated. The insurance plan is allowed to place all the claims during the last 60 days of the grace period in a pending status. The rule requires the insurance plan to notify the healthcare providers when an insured individual is in the last 60 days of the grace period.

This proposed regulation imposes a significant risk for uncompensated care on the healthcare providers. It does require insurers to tell healthcare providers when patients are behind on their premium payments, but it does not specify how the health plan will provide that notice to the providers. The only notice some providers receive will probably be the pending status placed on the unpaid claims by the insurance plan.

For a copy of the proposed regulation, please click on the link below:
http://www.law.cornell.edu/cfr/text/45/156.270