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CMS rejects 1332 waiver for 2018 Open Enrollment

The Connector submitted a 1332 waiver on Sept 8 looking for a way to address the uncertainty around Cost Sharing Reduction subsidies. Yesterday (Oct 23) CMS rejected the application as coming too close to the 2018 Open Enrollment period. https://www.cms.gov/CCIIO/Programs-and-Initiatives/State-Innovation-Waivers/Downloads/Preliminary-Determination-Incompleteness-MA.pdf
 
This is no surprise. On Oct 19, the Connector had already decided to use higher premium rates for 2018 based on the assumption that there would be no cost-sharing reduction payments made in 2018. 
 
The estimated 270,000 people eligible for ConnectorCare (0-300% FPL) or for Advance Premium Tax Credits only (300-400% FPL) pay premiums based on a percentage of income not the underlying full premium cost. They should be fine despite the increase in full premium costs in 2018.
 
People with unsubsidized plans through the Connector in 2017 will face higher premiums in 2018 & will be well advised to shop around  including looking at the cost of 2018 plans purchased directly from their insurance companies.
 
The Connector reports about 80,000 people now enrolled through the Connector will be eligible for unsubsidized plans in 2018.. This includes about 50,000 people who were eligible for ConnectorCare/APTC in 2017 but who received a preliminary determination that they will not qualify for subsidized coverage in 2018 based on various data matches related to income or tax filing. Some of these individuals may still be eligible for ConnectorCare or APTCs but will have to take action to update or correct their information with the Connector in order to get a corrected decision.
 
In Mass. Open Enrollment is Nov 1, 2017 to Jan. 23, 2018. This is the window for individuals to buy insurance on their own for 2018 either through the Health Connector or directly from commercial insurance carriers. 
 
The Connector's 1332 waiver request is a totally different animal from MassHealth's 1115 waiver requests. There has been no CMS action to date on the two pending 1115 MassHealth waiver applications.
 

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