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Enrollment and Eligibility (ENR) FAQ

Guidance for FAQ regarding Notices and Issuer Notices

Program Area: Enrollment and Eligibility (ENR)

Question: What is the content, format and timing of a delinquency grace period notice or should Issuers just send CMS an 834 termination file for an enrollee who has not made their past due premium payment and is no longer in a grace period?

Answer: In accordance with 45 CFR 156.270(d)(3), if an enrollee is receiving APTC and fails to make full payment (or payment within the optional premium payment threshold) of their portion of the monthly premium by the due date, the QHP issuer must generate a notice for non-payment of premium to the enrollee. CMS provided an example of this notice in Appendix C of the draft version of the Enrollment Operational Policy & Guidance released on October 3rd. The specific wording and messages included in the example are included as recommendations. Further, 45 CFR 156.270(d) requires QHP issuers to observe a 3 month grace period for enrollees receiving APTC and should not generate an 834 termination file until the grace period has expired and the enrollee has not paid their full premium during the grace period. Additional information can be found in Section 5.0 of the draft guidance.

Issued by: Centers for Medicare & Medicaid Services (CMS)

Issue Date: January 09, 2014

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