Get ready for subsidized care — I’m talking both subsidized health exchange premiums courtesy of your tax dollars, and the very real possibility that you’ll be further subsidizing exchange participants’ care 100% on the dollar.
Although the Affordable Care Act requires that an insurer must give three months’ notice to subsidized healthcare exchange participants who fail to pay their share of premiums before the insurer can cancel coverage, the insurer has no obligation to pay for the participants’ care after the first month of that three month period.
So, who pays for care if the participant doesn’t reinstate his coverage on time: You do.
To complicate matters, these people will be “covered” the entire time, at least in terms of having coverage in place. However, they’ll have actual coverage…the kind that you can put in the bank…only for the first month. So, you’ll only learn that you’ll be stuck after the fact.
In fact, it’s conceivable that the carrier will pay you, only to claw the payment back after the entire three month period runs without reinstatement, due to no legal liability to have made the payment in the first place.
What’s this mean for you, other than, of course, that you’ve become a social welfare agency?
You must review all payor contracts for the way that they impact your liability under these circumstances and renegotiate if necessary. For hospital based groups, consider ways to shift risk to the hospital as a part of your exclusive contract negotiations.