Changes to Medicare Advantage enrollment periods

Sept. 10, 2010

Beginning in 2011, Medicare Advantage subscribers will see changes in the enrollment periods during which they can choose a plan.

In previous years, Medicare Advantage subscribers had two opportunities to change plans or insurance providers. The Patient Protection and Affordable Care Act (PPACA) states that Medicare Advantage subscribers will now have one opportunity, unless they have special circumstances.

As usual, the annual election period this year will occur between Nov. 15 and Dec. 31. During this time, subscribers can:

• Enroll in a Medicare Advantage plan 
• Change Medicare Advantage plans 
• Enroll in a Part D prescription drug plan 
• Change their Part D prescription drug plan 
• Return to Original Medicare 

Changes made during this period are effective on Jan. 1, 2011.

In the fall of 2011, the annual election period will be held Oct. 15 through Dec. 7. Subscribers will still have the same opportunities to choose or change their plan during this time. Changes made will be effective on Jan. 1, 2012.

The open enrollment period that was formerly held between Jan. 1 and March 31 has been eliminated under PPACA. Instead, the new legislation provides for a 45-day annual disenrollment period from Jan. 1 through Feb. 14. During this time, subscribers can drop their Medicare Advantage plan and return to Original Medicare. They can also select a stand-alone prescription drug plan if they are returning to Original Medicare, regardless of whether the Medicare Advantage plan they are dropping did or did not cover prescription drugs. Subscribers will no longer be able to switch Medicare Advantage plans during this period.

Special enrollment periods still provide an opportunity to enroll in or switch plans outside of the annual election period. Below is a list of the most common situations in which a subscriber may be eligible to enroll during a special enrollment period. There are other situations that are not listed here where a subscriber can enroll during this period.

• If they permanently move outside their plan’s service area. They may change plans one month prior to their move and two months afterward. 
• If they lose coverage from their employer group, group retiree plan or COBRA. Subscribers are entitled to a special enrollment period that begins the month they are advised of their loss of creditable coverage. This special enrollment period ends two months after their loss of creditable coverage. 
• If they qualify for extra help (known as low-income subsidy benefits) to pay for their prescription drug costs, and they don’t receive Medicaid benefits. Subscribers may enroll in a Part D plan during a special enrollment period that begins the month they become eligible for low-income subsidy, and lasts as long as they are eligible for low-income subsidy. This special enrollment period allows subscribers to enroll in, or disenroll from, a Part D plan at any time. 
• If they receive any type of assistance from the Medicaid program. This includes individuals often referred to “full dual eligible” (enrolled in both Medicare and Medicaid), and partial duals who receive only cost sharing assistance under Medicaid. This special enrollment period begins the month they becomes dually-eligible and exists as long as they receive Medicaid benefits. This special enrollment period allows an individual to enroll in, or disenroll from, a Part D plan. In addition, those who are no longer eligible for benefits under Medicaid will have a special enrollment period beginning with the month they lose eligibility, plus two additional months, to make an enrollment choice in another prescription drug plan, a Medicare Advantage Prescription Drug plan, or to disenroll entirely from Part D.

The information on this website is based on BCBSM's review of the national health care reform legislation and is not intended to impart legal advice. Interpretations of the reform legislation vary, and efforts will be made to present and update accurate information. This overview is intended as an educational tool only and does not replace a more rigorous review of the law's applicability to individual circumstances and attendant legal counsel and should not be relied upon as legal or compliance advice. Analysis is ongoing and additional guidance is also anticipated from the Department of Health and Human Services. Additionally, some reform regulations may differ for particular members enrolled in certain programs such as the Federal Employee Program, and those members are encouraged to consult with their benefit administrators for specific details.