Medicare-ACA double dipper hunting season starts now

Managers of the Affordable Care Act exchange programs are trying to find people who have overlapping major medical coverage from Medicare and the Affordable Care Act public exchange system.

The exchange program managers have already started mailing warning notices to consumers who turn up in the results from a Medicare and ACA exchange data-matching program, according to officials at the Centers for Medicare & Medicaid Services (CMS).

Federal laws and regulations prohibit people from getting both Medicare Part A hospitalization coverage and ACA exchange plan premium tax credit subsidies at the same time.

The same rules prohibit people from using both Medicare Advantage plan coverage and ACA premium tax credit subsidies at the same time.

For years, many public health programs and group health plan sponsors have tried to shut out people who have access to other, comparable sources of coverage.

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Program managers have worked to weed out dual eligibles, or dual enrollees, partly to hold down program costs.

Program managers have also worried that people who are eligible for two different types of coverage and consciously choose the less obvious option may be people who are likely to have serious health problems.

Drafters of the ACA had a third reason to shut out dual enrollees: They wanted to keep new ACA health coverage expansion programs from crowding out the coverage provided by the programs that were in place before 2010, when President Obama signed the two bills that created the ACA.

For consumers, the arrival of data-matching notices could lead to fear and confusion. Consumers who ignore the Medicare-exchange data matching could end up having to pay some or all of the ACA premium tax credit subsidy help they have received back to the government, officials say.

For agents and brokers, the wave of notices could create opportunities to reach out to older prospects and strengthen ties to older clients.

For a look at some of what CMS officials have said about the program, based on a webinar slidedeck and notes posted on the semiprivate CMS Regtap website, read on.

What if some clients love their exchange plans? CMS has a solution. (Photo: Thinkstock)

1. Will all consumers who have Medicare coverage get the notices?

Exchange program managers could simply miss some people who have both Medicare coverage and ACA exchange plan coverage.

Exchange managers are consciously leaving Medicare enrollees under age 65 off the notice list.

Exchange plan enrollees who have Medicare coverage because they have a serious disability or because they are getting kidney dialysis will probably not get a data-matching notice, officials say.

2. What about consumers who are using Medicare in an unusual way?

Most U.S. residents ages 65 and older get Medicare Part A hospitalization free because they or their spouses have worked enough hours, and paid enough payroll taxes, that the government classifies them as having paid all that they need to pay for the Part A coverage.

A few people who have not worked enough hours in the United States to qualify for free Part A coverage, and have never been married to anyone who worked enough hours to qualify for free Part A coverage, pay a premium for the Part A coverage.

Consumers who have to pay for Medicare Part A coverage, or would have to pay for it if they signed up for it, can get ACA exchange plan premium subsidies, officials say.

But consumers who are actually paying a premium for Part A coverage must stop paying for the Part A coverage to qualify for the premium subsidies, officials say.

3. What if older consumers love their exchange plan coverage?

People who are eligible for free Medicare Part A coverage but would rather have an ACA exchange plan can stick with the ACA exchange plan.

The consumers who do that will have to pay the full cost of the exchange plan coverage out of their own pockets, without help from the ACA premium tax credit subsidy, officials say.

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