Key Takeaway: Early summer 2015, the Marketplace started sending reminder notices to consumers determined eligible to enroll in a Qualified Health Plan (QHP) with financial help and potentially have access to other minimum essential coverage (MEC) (i.e. private insurance through an employer, Medicaid, Medicare, the Veterans Administration, and the Peace Corps), as well as to consumers who have indicated an American Indian and Alaska Native (AI/AN) status on their Marketplace application. The notices reminded these consumers to resolve such MEC and AI/AN status Data Matching Issues (DMIs) as soon as possible. If they fail to do this, their financial assistance, including Advanced Premium Tax Credits (APTC) and/or specialized Cost Sharing Reductions (CSRs), could end as early as September 1st. Assisters can help consumers review their eligibility and reminder notices to determine if they have a DMI, determine when their documents are due, and help them submit documents to the Marketplace. Please note that the MEC and AI/AN DMIs only impact a small number of consumers and therefore assisters should not expect a lot of activity related to these DMIs.
Background: Data Matching Issues (DMIs) occur when the Marketplace cannot confirm the information that a consumer submitted as part of his or her Marketplace application. To resolve a DMI, the Marketplace will request that a consumer submit additional information. It is critical that consumers submit this additional information as soon as possible. If they do not, consumers with immigration or citizenship DMIs may lose eligibility for coverage through the Marketplace, and consumers with income DMIs may experience a modification of their APTCs and CSRs. Consumers with DMIs related to access to other MEC (both employer-sponsored and non-employer-sponsored) may lose all financial assistance, including both APTC and CSRs, and consumers with AI/AN DMIs will lose access to special Cost Sharing Reeducations (CSRs) they were receiving based upon their AI/AN status.
NEW: As part of the Marketplace health coverage application, the consumer must respond to questions regarding access to other coverage and AI/AN status. If the consumer’s application information about access to other coverage does not match information from the Marketplace data sources, a MEC DMI will occur. And, for those consumers who attest to having AI/AN status, an AI/AN DMI will occur because the Marketplace cannot run a real-time check on consumers’ AI/AN status. In these circumstances, the Marketplace is sending notices to consumers who potentially have access to other minimum essential coverage and to consumers who attest to AI/AN status DMIs to remind them to resolve these DMIs.
Like with other DMIs, affected consumers are initially mailed an eligibility notice if they needed to send the Marketplace more information. This eligibility notice would tell them that they have 90 days from the date of the eligibility notice to resolve the DMI. Consumers who have DMIs then receive a 60-day notice, a 30-day notice, and a reminder phone call from the Marketplace 14 days before their deadline to remind them to resolve the data matching Issue. The subject line of the notice says “Important: Submit documents by the dates below to keep your Marketplace health coverage or the help you are getting to pay for your Marketplace health coverage.” Specifically for DMIs related to other MEC coverage and AI/AN status, the Marketplace started mailing 60-day reminder notices to consumers in late June and 30-day reminder notices in late July. Depending on consumers’ communication preferences, consumers may also receive messages via email.
Many consumers have already submitted their documents to resolve these DMIs. However, consumers who have received these notices and have not provided appropriate documentation to resolve their MEC coverage or AI/AN status DMIs must do so by the deadline (in some cases as early as September 1, 2015). Consumers who fail to resolve their MEC DMIs in time may lose all financial assistance, including both APTC and CSRs. Similarly, consumers who fail to resolve their AI/AN DMIs in time will lose access to special CSRs they receive based upon their AI/AN status. To provide resolution to a DMI, a consumer must submit documentation to the Marketplace. If the Marketplace is able to verify the consumer’s eligibility for coverage and/or financial assistance based on the documentation, the DMI is resolved.Further detail regarding each specific type of DMI is discussed below.
- Employer Sponsored Coverage (ESC) MEC: If consumers are enrolled in ESC, or are eligible for ESC that is affordable and that meets the minimum value standard, then they are not eligible for APTC and CSRs from the Marketplace.
- Non-Employer Sponsored Coverage (Non-ESC) MEC: If consumers are eligible for public non-employer-sponsored MEC (i.e. Medicaid, Medicare, CHIP, coverage from the Peace Corps, or Veterans’ benefits), then they are not eligible for APTC and CSRs from the Marketplace. This is true even if the consumer is not enrolled in that public coverage.
- American Indian/Alaska Native (AI/AN) Status: Consumers who are members of federally recognized tribes qualify for AI/AN status. When their income is between 100% and 300% of the Federal Poverty Level (FPL), they are eligible to have zero out of pocket costs. Tribal members and Alaska Native Claims Settlement Act (ANSCA) shareholders, regardless of income (less than 100% FPL or above 300% FPL), do not have to pay any out-of-pocket costs for items or services provided by the Indian Health Service, tribal programs, or urban Indian programs (known as I/T/Us) or through referral to a QHP under Purchased or Referred Care. All consumers who attest to having AI/AN status and who did not provide documentation to support that attestation will have to submit supporting document(s). The Marketplace has been verifying status with documents submitted to date.
- Note: Those AI/AN consumers who have already submitted, or will submit, adequate documentation to verify their AI/AN status will not need to resubmit documentation in future years.
What Assisters Can Do:
We encourage assisters to:
1. Continue to help consumers review their notices from the Marketplace to identify if members of the household have a DMI and if so, when their documents are due. Remember consumers may have more than one DMI and may need to submit multiple documents. Below is an example of the information that will appear in the eligibility notice for various DMIs.
2. Help consumers submit the required information to the Marketplace. You can find the list of documents that a consumer should submit here. Also, the chart below outlines which documents a consumer can submit if they have an AI/AN Status, non-ESC, or ESC DMI.
3) Below are some general tips when completing the application and submitting documents to the Marketplace:
- Confirm SSNs are entered and correct for all members of the household. Remember that non-applicants are not required to provide their SSNs, but are strongly encouraged to do so if possible.
- Remind consumers to report changes to the Marketplace within 30 days of when they occur before and after they complete their application.
- Help consumers identify which type of DMI they or their household have, which members of the household are impacted, and which documents they need to submit for their DMI.
- Encourage consumers to upload their documents instead of mailing them in. If the documents are uploaded successfully, they should show up as “submitted” under application details right away.
- Remember not every document that consumers may want to upload is included in the drop-down menu of “Document Types” viewable after clicking Verify in the Application Details section of their My Account. If consumers need to upload a document that’s not listed, they should choose “Other” from the list.
- Tell consumers that they should only mail copies of documents, not their originals. When they mail copies of documents, they should include the barcode from their DMI notice and also include their name, state, and application ID on any documentation.
- Double-check that copies of documentation being sent to the Marketplace are clear, legible, and can be recognized as official documents.