Reform Alert - News from the Blues' Office of National Health Reform

CMS announces SHOP enrollment will be direct through issuers

Updated to previous alert from: June 26, 2014 SHOP Employee Choice

Dec. 2, 2013

On Nov. 27, the Centers for Medicare and Medicaid Services announced that, effective immediately, employers who desire to enroll in a qualified health plan or QHP in the Federally-facilitated SHOP Marketplace or FF-SHOP may do so directly with issuers or agents/brokers. Until otherwise notified, this approach will be the only option available until SHOP open enrollment begins Nov.15, 2014.

CMS has provided an expanded Plan Compare tool on Healthcare.gov that allows employers to enter the ages of their employees to get more precise premium information.

How does the enrollment process look?

  1. The employer completes the issuer-specific enrollment application and the SHOP eligibility application.
  2. The employer then submits the SHOP eligibility application for CMS approval. Issuers can help with completing the application.
  3. CMS will provide an eligibility determination to the employer by phone or email and by regular mail if requested. If CMS determines the employer is ineligible for the SHOP, it will notify the employer, including information on appeals.

Does a small business need to submit a SHOP eligibility application?

The SHOP eligibility application is only required if a small employer wishes to have access to the Small Business Health Care Tax Credit in 2014. Small employers have access to the SBTC if they purchase employee coverage through the SHOP, and meet certain other requirements.

How long will it take to receive an eligibility determination from CMS?

CMS has a backlog of eligibility applications submitted during October and November. These responses should be issued in early December. Once the backlog is cleared, CMS expects to issue determinations within 3 to 5 days of receiving a fully completed SHOP eligibility application. If the SHOP can’t determine whether a business is eligible, it will contact the employer to resolve any outstanding issues.

When can employees enroll for coverage?

Employees can enroll in the plan prior to the employer receiving an eligibility determination from CMS. Minimum participation rules may still apply. In the FF-SHOP, minimum participation is 70 percent. The participation requirement is waived from Nov. 15 to Dec. 15 each year. Premium aggregation and employee choice will be available Oct. 1, 2014, (in time for employers starting renewals 90 days out from first renewal date of Jan. 1, 2015).

How does a small business claim the small business tax credit?

The SHOP will notify the IRS of businesses enrolled in SHOP QHPs through the enrollment process, provided the employer submits the SHOP eligibility application. This will be done in time for the employers to claim the SBTC. You can read more about the SBTC in our Oct. 15, 2013, Reform Alert.

When will testing begin?

CMS advised they aim to begin testing for SHOP as early as July 1, 2014. CMS hopes to have technical webinars prior to that time. CMS will do additional planning on several issues and as a result, more changes may occur as this develops.

Where can I find more information?

More information can be found on the Centers for Medicare and Medicaid Services website.

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