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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: Will the FF-SHOP validate Special Enrollment Period (SEP) reasons, such as legal guardianship? Is the issuer expected to maintain enrollment of plan members using the ASC X12 834 enrollment transaction, or is there additional validation for the issuer to perform?

Answer: No, the FF-SHOP will not validate SEP reasons at the time of enrollment. Information provided by an employee regarding their dependents is signed under the penalty of perjury. In addition, CMS may conduct dependent verification audits. Any QHP issuer participating in the FF-SHOP must maintain enrollment of members in accordance with 45 C.F.R. 156.285.

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

Issue Date: July 30, 2013

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