Thursday, September 22, 2011

Plan Non-Renewal Special Enrollment Period

Each year, Medicare Advantage and Part D plans have the option not to renew their contracts with Medicare.  Enrollees in plans that are not being renewed have certain rights depending upon the circumstances under which their plan is leaving the Medicare program.[8]  Plans that are not renewing for 2012 must notify enrollees in writing no later than October 2, 2011.[9]

A special enrollment period (SEP) exists for members of MA and Part D plans that will be affected by plan or contract non-renewals and plan service area reductions that are effective January 1 of a contract year. The change in the time period of the ACEP also affects the timing of the SEP.  The Plan Non-Renewal SEP begins December 8 and ends on the last day in February of the following year. Enrollment requests received from December 8 through December 31 will have an effective date of January 1. Enrollment requests received in January will have an effective date of February 1. Enrollment requests received in February will have an effective date of March 1.[10]  (Note that the duration of this SEP extends beyond the last day of the MADP discussed above – through the end of February as opposed to February 14th.  Also note that CMS-approved plan consolidations are neither terminations nor non-renewals, thus individuals affected by plan consolidations are not eligible for the SEP for non-renewals or terminations.) 

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