Online SHOP enrollment transition relief extended, states should plan for 2019

State-based Small Business Health Options Programs (SHOP) that have not yet provided online enrollment capabilities are permitted to use direct enrollment for plan years beginning in 2017 and 2018. CMS and the Center for Consumer Information & Insurance Oversight (CCIIO) is providing this extension as a transitional measure, available only to SHOPs that currently use direct enrollment.

Requirements. SHOPs using the direct enrollment method are responsible for ensuring that enrollment and coverage operate as follows:

• the employer applies for and receives a favorable eligibility determination from the SHOP;
• eligible employees and dependents enroll in a SHOP qualified health plan (QHP); and
• the SHOP QHP issuer’s enrollment is conducted in compliance with rules and policies.

State-based SHOPs intending to continue with direct enrollment must submit a plan to CMS ensuring that the approach will meet these criteria.

Future plans. For plan years beginning in 2019 and later, state-based marketplaces must either offer online functionality or have an appropriate alternative in place. State-based marketplaces are permitted to use the federal information technology (IT) platform for SHOP eligibility and enrollment functions. CMS also encourages states to share SHOP IT solutions with other states. Additionally, section 1332 of the Patient Protection and Affordable Care Act (ACA) allows states to submit a State Innovation Waiver. This waiver will allow states to be exempted from certain ACA provisions, as long as the proposed changes will provide comparable coverage and access to coverage. States intending to submit a SHOP waiver pertaining to online enrollment must demonstrate that the provisions of the proposal will offset the effect of not having online functionality.

Other considerations. All SHOPs must provide employers the option to offer all QHPs at a single actuarial value, but state-based shops may implement additional employee choice models, such as all QHPs in the SHOP or all QHPs available from a single issuer at all actuarial values. Employers that intend to claim the Small Business Health Care Tax Credit must be eligible for SHOP participation and enroll employees in SHOP certified coverage.

SOURCE: CCIIO Notice, April 18, 2016.

Visit our News Library to read more news stories.