Small Business Health Options Program (SHOP) FAQ

Guidance for FAQ regarding Employer/Employee Interaction and Special Enrollment Periods (SEPs)

Program Area: Small Business Health Options Program (SHOP)

Question: In the FF- SHOP, will the effective date of coverage always be the first of the following month if an initial enrollment application is received by the 15th of the month? Additionally, would the effective date of coverage be the first day of the following month if an enrollment application is received after the 15th of the month (with an exception for birth or adoption of a child where the effective date is the day of the qualifying event)? Will the FF-SHOP allow for retroactive enrollment?

Answer: For groups enrolling for the first time, the effective date of coverage is based on when an employer submits the initial application. An employer must enroll by the 15th of the month to effectuate coverage on the first of the following month. An employer that enrolls after the 15th will have their coverage effectuated on the first day of the next month. For example, an employer that enrolls on March 17th will have an effective date of May 1st. For special enrollment periods, the effectuation date will depend on the employee's specific situation. See 45 CFR 155.420(d) of the HHS Final Exchange Establishment Rule (http://www.gpo.gov/fdsys/pkg/FR-2012-03-27/pdf/2012-6125.pdf) for applicable employee circumstances. There are instances where the effective date of coverage will be retroactive. For example, the effective date for the birth or adoption of a child is always the date of the qualifying event, regardless of when an issuer is notified, and as long as the FF-SHOP is notified within 30 days of the event.