October 1, 2014
The second-year enrollment cycle is about to start for the Health Benefit Exchanges, on November 15, 2014.
At this point, it is not clear whether the new-enrollment and repeat-enrollment efforts will go well, or will be riddled with problems.
As enrollment unfolds, insights can be gained by watching the Year 2 cycle from all viewpoints combined, so that all the activities can be understood and partial reports can be assembled together.
For a large, complex program like the ACA, there needs to be a comprehensive information-handling strategy that extends over all aspects of the effort, and is “put into place” and “made to work”.
This type of balanced operation never “fell into place” for the Year 1 efforts.
Stage 1 of enrollment begins with effective outreach to the desired public groups, and efficient ways to bring potential enrollees into the enrollment process.
The next stage is for the computer systems to collect and process sign-up information.
The third stage is for the Exchange computers to do a good job at communicating with other agencies, like the Internal Revenue Service, in order to perform what are very complicated eligibility and subsidy calculations.
The fourth stage is for accurate output information to be passed along to insurance companies and providers—and back to the enrollees themselves.
All four of these stages must work well—and together—if the Year 2 enrollment is going to be a success. Any areas of weakness will compromise the entire effort.
A sustained push is required “across the board”.
Attorneys can watch performances at all four stages to get an advance estimate of how things are going.
If there are criticisms about outreach to new and repeat enrollees, enrollment targets are unlikely to be met.
If computer processing struggles, there will be a pileup of information inside the Exchanges, with little or reduced output or output filled with errors.
If linkages to other agencies don’t work well, processing will be slowed and inaccuracies will be built into the outputs.
And if insurance companies and providers complain that they are unable to effectively deal with Exchange outputs, uncertainties over coverage may reach crisis levels.
Attorneys can mount their own evaluation efforts by keeping track of this 1-2-3-4 overview of the Year 2 enrollment. They may then be better prepared to help clients anticipate—and begin to respond to—problems before the “general picture” begins to emerge.
More information about implementation of the Affordable Care Act and associated legal practice issues may be found in recent books on the ACA and on the health care system, other postings to this blog, and on the ACA Blog, also written by the author of this series.