Batch Auto Reenrollment (BAR) and Open Enrollment (OE) Updates
Updates on Batch Auto Reenrollment (BAR) and Open Enrollment (OE) processes for the Center for Consumer Information & Insurance Oversight (CCIIO), including information on BAR progress, cancellation processes, switch files, and passive cancels. Issuers are provided with details on handling 2021 enrollments, active selections for 2022 coverage, and necessary job runs.
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Batch Auto Reenrollment (BAR) and Open Enrollment (OE) Center for Consumer Information & Insurance Oversight (CCIIO) December 6, 2021 https://www.regtap.info/FFENR.php The information provided in this presentation is not intended to take the place of the statutes, regulations, and formal policy guidance that it is based upon. This material summarizes current policy and operations as of the date it was uploaded to RegTap. Links to certain source documents may have been provided for your reference. We encourage persons taking the course to refer to the applicable statutes, regulations, and other interpretive materials for complete and current information. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, unless specifically incorporated into a contract. This document is intended only to provide clarity to the public regarding existing requirements under the law. This communication was printed, published, or produced and disseminated at U.S. taxpayer expense.
BAR Updates An incremental run of BAR, which will auto-renew 2021 enrollments created since early October as well as carry forward 2021 updates reported by enrollees after October BAR, was run last week. Issuers received BAR files on or after Monday November 30 for several days until the run was completed. The BAR Progress report has been paused until the Incremental BAR Run resumed. Afterwards, BAR Progress report will be paused again. CMS ran the Cancel Carry Forward job on 11/29-11/30. This cancelled auto re- enrollments that are subsequently ineligible for BAR due to late terminations of current year Marketplace coverage. These files are sent as I834 s with an AMRC of CANCEL-CARRYFORWARD. CMS also ran the CIC Carry Forward job on 11/29-11/30. This job carried forward changes made on the current year policy to the future year auto- reenrolled policy if the future year policy is still in passive status (origin =11). If the future year subscriber and Plan ID remain the same, then the EFT code will vary governed by the M834 Operations Manual. If the change is not M834 eligible, then the EFT is CANCELCIC/CIC. 2
Switch File Issuers continue to receive the Switch File. It will list current year consumers who have not been BAR d and have made an active selection to a different issuer for 2022 coverage. Issuers should non-renew coverage for consumers on the Switch File. It is sent via EFT SWTFL. The Switch File will run until 12/16 When a consumer makes an active selection, the losing issuer will be informed of the change through a cancel/term transaction or the Switch File, and the gaining issuer will receive an initial enrollment transaction. 3
Passive Cancels Passive Cancels Will cancel passive reenrollments that duplicate active enrollments for future year Marketplace coverage. Deliveries in December: 12/3 & 12/20 (this Wednesday) EFT BARCN2 jobs (IPA layout) Issuers may alternatively send a IC834 cancel on the duplicate 2022 passive (BAR) rather than waiting for the BARCN2 job 4
Passive Cancels Passive Cancels Incremental Pre-Audit (BARCN2) Files were distributed to Issuers on Friday, December 3rd The cancels sent on these BARCN2 Files will also be reflected as Overlap Cancels on the Comprehensive 2022 Pre-Audit (AUD2) Files 5
Cancel Carry Forward Description: Will cancel auto-reenrollments that are subsequently ineligible for BAR due to late terminations of current year Marketplace coverage. Delivery Date: Intermittent 12/16+, then twice monthly January thru March Delivery Code/Layout: Delivered to issuers via EFT I834 s with AMRC of CANCEL-CARRYFORWARD 6
CIC Carry Forward Carries forward to the future year enrollment changes effective after BAR Delivery Date: 12/16+ Delivery Code/Layout: 1) If the future year subscriber and Plan ID remain the same, then varies (governed by M834 Operations Manual) 2) If the change is M834 ineligible, then CANCELCIC/CIC 7
