CMS Extends Transitional Relief…Yet Again

On April 9, 2018, the Centers for Medicare & Medicaid Services (CMS) released a bulletin which extends its transitional policy to policy years beginning on or before October 1, 2019, provided that all such policies end by December 31, 2019. Previously, transitional relief was scheduled to end by December 31, 2018.

As provided in previous guidance, medical plans subject to transitional relief are not considered to be out of compliance with the ACA in regard to fair health insurance premiums or guaranteed availability and renewability of coverage.

CMS indicated that states may permit issuers that have renewed policies under the transitional policy continually since 2014 to renew such coverage for a policy year stating on or before October 1, 2019, as long as any policy renewed under the transitional policy does not extend past December 31, 2019. 

CMS will work with issuers and states to implement this policy, including options that would allow for short policy years or early renewals with a January 1, 2019 start date. This approach will facilitate smooth transitions from non-ACA medical coverage to ACA compliant coverage. We are awaiting guidance from the medical carriers on how they will administer the transitional relief extension for groups currently offering non-ACA compliant coverage.