This week, the Centers for Medicare & Medicaid Services (CMS) announced new opportunities for people to enroll in Medicare or make certain changes to their coverage during the coronavirus emergency. While these temporary policies are a step in the right direction, they are too narrow and leave some without relief. More needs to be done.
First, CMS made clear that there is a Special Enrollment Period (SEP) that will allow people to make changes to their Medicare Advantage (MA) and Part D enrollment under limited circumstances. This SEP allows people to make a change to their coverage if they already had a right because of a different SEP or the MA Open Enrollment Period, but did not exercise it in time due to the coronavirus emergency. Importantly, people must use this SEP by June 30.
This SEP does not help people who discovered, because of the health emergency, that their plan is not a good fit or who wish to change plans because of a coverage or other issue. As always, if a plan will not cover a particular medication or service that a person needs, they can seek an appeal.
CMS also announced a new basis for requesting Equitable Relief, which may enable some people who missed previous enrollment opportunities to enroll into Parts A and B. Like the coronavirus SEP, these provisions are overly narrow—only people who could have enrolled into premium Part A or Part B during the time period from March 17 – June 17 but did not can access this help. It is also quite short; people must request relief by June 17, 2020.
The announcement includes FAQs stating that coverage will be effective as if the person used the another applicable enrollment period, but it does not go into detail about how that will be applied. For example, it is unclear when coverage will start for some people who were in their Initial Enrollment Period. Such people may face gaps in coverage that are especially dangerous given the public health emergency.
While Medicare Rights appreciates CMS making these policies public and transparent, and we applaud CMS for realizing that enrollment-related flexibilities are needed, these actions do not go far enough. We are particularly concerned about the short timeline for equitable relief for premium Part A and Part B. Some individuals may not even realize that they made a mistake or missed their enrollment period, or they may not have the appropriate resources to seek relief by the June 17 deadline, especially if local Social Security offices and other avenues for assistance remain closed past that date. The need for additional enrollment protections remains.
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