Short-term health plans in Idaho
- Enhanced short-term plans in Idaho can have initial terms of up to 364 days and total duration of up to three years; nonrenewable short-term plans can have terms of up to 12 months.
- Short-term plans were previously defined in Idaho as being non-renewable, but new legislation signed into law in 2019 allows for enhanced short-term plans (available for 2020) that are guaranteed renewable and far more robust than traditional short-term plans.
- The enhanced short-term plan must abide by numerous state regulations.
- Before enhanced short-term health insurance in Idaho became available, consumers had previously received cautions from the state about the potential drawbacks of short-term plans.
- 3,769 people had short-term health insurance in Idaho in 2016. That has likely increased with the state’s new “enhanced” short-term plans.
- At least eight insurers offer short-term health insurance in Idaho.
- Idaho considered making enhanced short-term plans available through the exchange as of early-mid 2020, but no action has been taken on this as of late 2020.
Short-term health plan availability in Idaho
There are two different types of short-term health insurance plans available in Idaho:
- Traditional short-term plans that are non-renewable, not guaranteed-issue, and are available with a total duration of up to 12 months
- Enhanced short-term plans that are guaranteed-renewable, guaranteed-issue, and available with a total duration, including renewals, of up to 36 months. Idaho’s rules for these plans are extensive, and go well beyond the Trump administration’s regulations that took effect in 2018.
The enhanced short-term plans debuted in 2020, and are offered by Blue Cross of Idaho and SelectHealth. The traditional plans are also available from both of those insurers, as well as several other companies.
Until Idaho enacted new rules in 2019, state regulations clarified that if plans were renewable, they were subject to Idaho’s rules that apply to Idaho’s individual insurance market, including a requirement that the plans be guaranteed renewable. So short-term plans were defined in Idaho as being non-renewable (see Idaho insurance statutes, Title 41, Chapter 52).
[There is some uncertainty about the implementation of the state’s rules for non-renewable short-term plans. Some guidance indicates that they can durations of up to a year, while other regulations indicate that they are limited to no more than six months in duration. But at least some of the traditional short-term plans available in Idaho do have terms in excess of six months.]
Idaho’s short-term health insurance regulations
In 2018, Idaho tried to get CMS approval for “state-based” plans that would have skirted various ACA requirements and regulations. CMS rejected that proposal. But they indicated that the state could modify the proposal and use short-term health insurance rules in order to accomplish much of its goals without the need for additional federal approval.
So in April 2019, Idaho enacted legislation (H.275) that allows for the creation of “enhanced” short-term plans. While these plans are still required to have initial terms that are under 12 months, they’re renewable “at the option of the insured.” That’s an important distinction; the federal short-term plans regulations that were finalized in 2018 allow short-term plans to be renewable, but at the discretion of the insurer. Idaho’s new legislation requires insurers that offer “enhanced” short-term plans to let members renew their coverage.
In keeping with federal regulations, total plan duration, including renewals, cannot exceed 36 months. But H.275 also indicates that the insurer will have to allow a member to reapply for another policy after one policy ends and its renewal opportunities have been exhausted [see 41-5207(h)]. And the regulations the state has issued go even further, noting that “enhanced short-term plans must be reissued at the option of the enrollee, upon exhausting any renewability due to duration or age,” and that “no new application or questions concerning the health or medical condition of the covered individuals may be requested to effectuate the reissuance.” (emphasis added)
H.275 called for the addition of Section 5214 to Idaho Code Title 41, Chapter 52, which had been added by mid-2019. The legislation stated that the new rules would be effective immediately, and an April 2019 bulletin published by the Idaho Department of Insurance noted that short-term plans with “limited renewability” were likely to be available in Idaho by 2020.
Blue Cross of Idaho began selling enhanced short-term plans as of December 1, 2019, and SelectHealth also began offering the plans as of early 2020. Both insurers are continuing to sell enhanced short-term plans, as well as traditional short-term plans.
The Idaho Department of Insurance published a news release in 2016, cautioning residents about the potential drawbacks and limitations of short-term health insurance, while noting that the plans can be appropriate for people who missed open enrollment and don’t have access to a special enrollment period for ACA-compliant coverage. This was well before the state created the new “enhanced” short-term plan pathway, and although the drawbacks noted in the news release are still applicable to regular short-term plans, they mostly do not apply to the enhanced short-term plans.
Idaho’s requirements for enhanced short-term plans
Rulemaking activity for Idaho’s new enhanced short-term plans is available here. The state published temporary rules that took effect in July 2019, and a proposed final rule was published in October 2019. The Idaho Department of Insurance also published an at-a-glance guide to how enhanced short-term plans compare with traditional short-term plans, and the full set of rules that apply to traditional and enhanced short-term plans are available in Idaho Administrative Code Section 18.04.15.
- Insurers can choose to offer year-round availability or to limit enrollment to the same enrollment window that applies to ACA-compliant plans. If the plan is available year-round, the insurer can impose a waiting period for pre-existing conditions. If the plan is only available during open enrollment, no pre-existing condition waiting period can be applied (SelectHealth and Blue Cross of Idaho both offer plans that have waiting periods for pre-existing conditions).
- Insurers that offer enhanced short-term plans must also offer qualified health plans through Your Health Idaho (the state-run exchange) in the same areas.
- Enhanced short-term plans must be offered on a guaranteed-issue basis (but insurers can base premiums on medical history, and can impose a waiting period for pre-existing conditions).
- Coverage under an enhanced short-term plan is considered qualifying coverage that allows a person’s pre-existing condition waiting period to be waived. So if a person renews their short-term plan after the first year, there will no longer be any waiting periods for pre-existing conditions during the second year.
- Enhanced short-term plans must be guaranteed renewable (for up to 36 months of total duration). The insurer cannot require a new application or new medical history questions during the renewal process.
- Although the plans are capped at 36 months (in accordance with federal rules for short-term plans), insurers are required to allow enrollees to re-enroll in a new plan after the first one expires, and no new application or medical history questions can be used.
- When a person has had coverage under an enhanced short-term plan for at least 11 months and the policy is terminating, they are eligible to enroll in any of the insurer’s ACA-compliant plans at that point (regardless of whether open enrollment is underway).
- Enhanced short-term plans cannot vary rates based on gender, although they can use an applicant’s medical history to set rates.
- Geographic rating areas must be the same as the rating areas used for ACA-compliant plans.
- Enhanced short-term plan enrollees must be incorporated into the same risk pool as the insurer’s other individual market enrollees.
- Enhanced short-term plans must provide benefits in line with the state’s benchmark plan for essential health benefits, and cannot impose annual benefit caps under $1,000,000.
Regular non-renewable short-term health insurance in Idaho continues to be available with total durations of up to one year. They are not guaranteed issue, but premiums can only vary based on age, tobacco use, and zip code (this is generally how rating rules work for short-term plans nationwide; applicants are either accepted or declined based on overall medical history; if they’re accepted, the premiums are based on only a few variables).
In 2017, the Idaho Department of Insurance published an overview of health coverage in the state. As of 2016, there were 3,769 people with short-term health insurance in Idaho, which was a decrease of 13.3 percent since 2015. But Idaho’s new “enhanced” short-term plans, which became available for 2020, are very different from regular short-term plans. Overall short-term plan enrollment in the states could end up growing significantly as a result.
Which insurers offer short-term plans in Idaho?
Several insurers offer short-term health insurance in Idaho, including two that offer enhanced short-term insurance plans:
- Blue Cross of Idaho (enhanced “Access” short-term plans available, as well as traditional short-term plans)
- Companion Life
- Everest Reinsurance
- Life Map
- SelectHealth (non-renewable “transition” short-term plans are available, as well as enhanced short-term plans)
- Standard Life and Accident Company
- The North River Insurance Company/Crum & Forster (“Epic short-term health insurance”) — a new product; rates and forms are still under review by the Idaho Department of Insurance as of the fall of 2020; see SERFF filing CRUM-132564078.
More information about how each of these insurers is treating coverage and cost-sharing related to COVID-19 is available here.
Idaho has considered making enhanced short-term plans available via the exchange
Draft meeting minutes from a September 2019 and December 2019 board meetings for Your Health Idaho (the state-run health insurance exchange) indicated that the enhanced short-term policies were expected to be offered for sale via the exchange (without any premium subsidies) as soon as the second quarter of 2020. The meeting minutes noted that the exchange would have to sort out how the medical history questionnaires would be handled for those plans, as their pricing can vary based on medical history (unlike ACA-compliant plans).
Allowing enhanced short-term plans to be sold through the exchange would obviously be controversial. The ACA only allows qualified health plans to be sold through a state’s exchange, and these enhanced short-term plans — while certainly better than short-term plans in most states — are not qualified health plans. But the issue does not appear to have been brought up again during the 2020 meetings, and enhanced short-term plans are not for sale via Your Health Idaho as of late 2020.
In December 2019, Senators Patty Murray (D, WA) and Ron Wyden (D, OR), and Congressmen Frank Pallone Jr. (D, NJ) and Richard Neal (D-MA) sent a letter to CMS, asking them to step in and prevent Your Health Idaho from offering enhanced short-term plans through the exchange. They noted that the ACA only allows qualified health plans (QHPs) to be sold in the exchange. And while Idaho’s enhanced short-term plans offer much more robust coverage than a typical short-term plan, they are not QHPs.
[There was one error in the letter, however: It states that Idaho’s plans wouldn’t have to cover essential health benefits, when in fact, they are required to do so in accordance with the state’s benchmark plan.]
Who can get short-term health insurance in Idaho
Short-term health insurance in Idaho can be purchased by applicants who can meet the underwriting guidelines the insurers use.
Traditional short-term health plans typically include blanket exclusions for pre-existing conditions, so they will not be adequate for residents of the Gem State who need certain medical care for ongoing health conditions. Enhanced short-term plans are guaranteed-issue, but insurers can base premiums on a person’s medical history and can impose a waiting period before pre-existing conditions are covered.
If you need health insurance in Idaho, your first step should be to see if you’re eligible to enroll in an ACA-compliant major medical plan. These plans are available during the annual open enrollment period from November 1 to December 15, and during special enrollment periods triggered by a variety of qualifying life events. ACA-compliant plans are available through Your Health Idaho (the Obamacare exchange/marketplace in the state) or directly from the health insurance companies, although premium subsidies are only available through the exchange (if you’re eligible for a premium subsidy, you may find that your monthly premiums are far more affordable than you had expected).
ACA-compliant policies are purchased on a month-to-month basis, so you can enroll in one even if you keep it for only a few months until other coverage kicks in. So for example, if you’ll soon be eligible for Medicare or a new employer’s plan, you can still enroll in an ACA-compliant plan during open enrollment or a special enrollment period, and then cancel it when your new coverage takes effect.
But if you’re unable to enroll in an ACA-compliant policy, a short-term health insurance plan is certainly better than remaining uninsured. And Idaho’s enhanced short-term plans include far more consumer protections than the short-term plans that are available in most other states.
When should I consider short-term health insurance in Idaho?
There are certain situations where you may need to consider short-term coverage, such as:
- If you missed open enrollment for ACA-compliant coverage and don’t have a qualifying event for a special enrollment period.
- You’ll be enrolling in Medicare soon and don’t have access to an ACA-compliant individual or employer-sponsored plan in the meantime.
- You’ve enrolled in an ACA-compliant plan but have to wait up to several weeks before it takes effect.
- You’re newly employed but the business has a waiting period of up to three months before you can enroll in your employer’s healthcare plan.
- If you’re not eligible for Medicaid or a premium subsidy for an ACA-compliant plan, and need a more affordable option than a full-price ACA-compliant plan. People who are ineligible for premium subsidies include:
- Idahoans who earn incomes 400% above the federal poverty level. (For 2021 coverage, that amounts to $51,040 for a single person. If your ACA-specific modified adjusted gross income is just a little above the subsidy-eligible threshold, there are steps you can take to reduce it).
- People who are caught by the ACA’s family glitch.
- People who are ineligible to enroll in a plan through the exchange because they are not lawfully present in the US.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.