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A PHE doesn't typically affect eligibility for health coverage programs. However, the Families First Coronavirus Response Act mandates that any Medicaid agency (Oregon Health Plan, OHP, in Oregon) receiving certain federal funding must offer continuous coverage to all Medicaid enrollees. This means that people who are technically no longer eligible for OHP benefits due to a life change will not be disenrolled until after the continuous coverage provision ends. Certain verification factors can also be relaxed.
Under the 2023 omnibus bill, the federal government uncoupled the continuous coverage provision from the PHE. This means that OHP must begin the redetermination process no later than April 1, 2023, regardless of the status of the PHE. April 1 will mark the beginning of the “unwinding period."
During the unwinding period, Oregon Health Authority (OHA) and Oregon Department of Human Services (ODHS) will work together to redetermine clients' eligibility for state benefits, such as OHP.
Throughout the unwinding period, OHP will send notices to Oregonians who are enrolled in medical benefits. OHP enrollees will have 90 days to submit information to redetermine their eligibility for OHP.
People who are no longer eligible for OHP benefits will receive a 60-day closure notice. We estimate that around 300,000 Oregonians may no longer qualify for OHP benefits and will need to act elsewhere to enroll in health coverage. OHP will share data with the federal Marketplace and OHIM regarding enrollees who are no longer eligible for OHP benefits. The federal Marketplace and OHIM will contact clients to advise of coverage options through the Marketplace.
Losing OHP benefits will open a special enrollment period (SEP) to purchase a coverage through the Marketplace. The American Rescue Plan (ARP) and Inflation Reduction Act (IRA) expanded financial assistance eligibility to more people. For more information, visit OHIM's website at OregonHealthCare.gov.
OHA and ODHS are working collaboratively with the Community and Partner Workgroup (CPWG) to establish a timeline for when populations within Oregon will enter the redetermination process once the unwinding period begins. The CPWG is considering multiple factors that put current enrollees at greater risk, including the open enrollment period and the deadline to enroll to be included in automatic reenrollments.
OHP notice timelines will not be reflected in the ONE system or MMIS. OHP enrollees will receive a redetermination notice advising if they were able to be auto-redetermined based on recently submitted information, or if they must submit updated information to process their redetermination. The redetermination notice will allow 90 days to respond.
If a client is determined to be no longer eligible for OHP benefits, they will receive a 60-day closure notice which will clearly state a closure date.
The Oregon Health Insurance Marketplace (OHIM) will send information to people who are no longer eligible for OHP benefits advising of potential coverage options through the Marketplace. People who do not enroll through the Marketplace will receive a second notice from the federal Marketplace 30 days before their special enrollment period ends based on the date their OHP benefits end.
OHP notices will be sent based on the preferred communications methods selected during the OHP application process. Notices will also be available through the ONE system.
Marketplace notices will be sent via postal mail and additional contact mechanisms include text messaging, email, and phone calls, depending on communications preferences.
OHP members may submit changes to your information including contact and income information at any time by visiting ONE.Oregon.gov or by calling 800-699-9075 (toll-free).
Yes. Clients may contact ONE Customer Service Center at 800-699-9075 (toll-free) at any time and for any reason. Once the client has an end date for their OHP benefits they may apply for Marketplace coverage. Clients will be reassessed for potential OHP eligibility during the Marketplace application process. If they fall within OHP income limits, they may be referred to the state for final determination. If the client is outside OHP income limits and otherwise qualify to enroll through the Marketplace, they can select a plan and enroll.
Typically, a client would only be eligible for a “loss of coverage" SEP if they lost health coverage involuntarily. Before April, if a client voluntarily cancels their OHP plan they will qualify for a “loss of coverage" SEP based on self-attestation and will not be asked for proof of the loss. After April, during the unwinding process and beyond, the Marketplace is expected to revert to the traditional guidance. This means a client must involuntarily lose coverage to qualify for a “loss of coverage" SEP and may be asked to provide proof of the involuntary loss of coverage.
On Jan. 27, 2023 CMS announced a new SEP called an “Unwinding SEP." This new SEP allows individuals to enroll in Marketplace health coverage outside of the annual open enrollment period. HealthCare.gov will be updated so that Marketplace-eligible individuals who submit a new application or update an existing application between March 31, 2023 and July 31, 2024; and attest to a last date of OHP coverage within the same time period, are eligible for an Unwinding SEP. Individuals who are eligible for the Unwinding SEP will have 60 days after they submit their application to select a Marketplace plan with coverage that starts the first day of the month after they select a plan. Individuals losing minimum essential coverage (MEC), such as OHP benefits, may report that loss of coverage up to 60 days before their last day of OHP.
No, but HealthCare.gov has made updates to the existing application questions that asks about a recent loss of Medicaid or CHIP coverage and updated existing functionality to grant the Unwinding SEP to eligible individuals. Individuals can also be determined eligible for the Unwinding SEP through existing questions on partner applications that ask about a recent loss of Medicaid or CHIP coverage.
The Unwinding SEP will be available to Marketplace-eligible individuals who:
To help avoid gaps in coverage during unwinding, it is recommended that individuals who have received notice from OHP that they are no longer eligible for benefits submit a new application or update an existing application on HealthCare.gov as soon as possible. This recommendation also applies to individuals whose OHP coverage was terminated due to procedural reasons, so that the Marketplace can evaluate their eligibility for OHP or Marketplace coverage with financial assistance.
Individuals will not be required to submit documentation of a qualifying life event to be eligible for the Unwinding SEP. Applicants will be required to attest to a loss of Medicaid or CHIP coverage as part of the application.
OHA and ODHS have been working collaboratively and taken recommendations from the CPWG, established for the unwinding period. Based on feedback from CPWG, a comprehensive communications and engagement plan is being developed to ensure all Oregonians affected by the unwinding receive the information they need. Oregon will also work with trusted community partners to ensure their clients are able to be reached.
Oregon's goal is to work closely with trusted community partners and insurance agents/brokers to ensure all affected Oregonians receive the information and assistance they need to act appropriately.
It is essential that OHA and ODHS has current contact information for all members to communicate effectively during the unwinding period. You can encourage clients to update their contact information by logging in to ONE.Oregon.gov or calling 800-699-9075 (toll-free).
You can find OHA/ODHS produced resources at https://bit.ly/OHAPHEtools, including a toolkit and webinar series for partners. Marketplace resources can be found at https://orhim.info/resources and will be updated as new tools are made available. We encourage community partners and insurance agents/brokers to join the Marketplace Groupsite (https://ohim.groupsite.com) to stay informed about news, events and resources.
Yes! The Marketplace Transition Help Center can help Oregonians needing help:
Yes, in this situation, the client could submit a new application and receive the Unwinding SEP.
As long as a client is losing Medicaid or CHIP coverage due to Unwinding submits or updates an existing application between March 31, 2023 and July 31, 2024, and attests to losing Medicaid or CHIP coverage during the same period, they will receive the Unwinding SEP.
The Marketplace Transition Project team is sending letters to people who are determined to be no longer eligible for OHP benefits close to their 60-day closure notice. The letter the member recieves will depend on their unique situation. You can view the letters and inserts below.
The federal Marketplace will also be sending text messages and making calls to people who have not taken action 30-days of their OHP eligibility decision. Once an individual starts a HealthCare.gov application, they will begin to receive typical mid-application, post-application/pre-enrollment, or post-enrollment messaging.
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