This was originally posted on the CHIRblog.

Lost your job? Moving to a new area? Having a baby? Make sure you have documentation of these life events if you want health insurance through healthcare.gov. Recently announced, the administration will now require verifying documents from consumers who enroll or change their plans using a special enrollment period in 2016 through the federal platform. Although the detail of this process is forthcoming, the administration will require consumers to upload or to mail documents verifying the following life events:

• Loss of minimum essential coverage or loss of another type of health insurance,
• Permanently moving to an area where an individual will have access to new health plans,
• Birth,
• Adoption or child support or court order,
• Marriage.

The administration is making this change in response to insurer complaints about special enrollment periods and the lack of a process to verify SEP eligibility. And the administration is between a rock and a hard place: it’s trying to appease insurers participating in healthcare.gov while trying to provide as many opportunities as possible for individuals to enroll. But this new approach with special enrollment periods raises many concerns for consumers, and could slow overall Marketplace enrollment.

First, if you’ve ever worked with consumers trying to resolve data matching inconsistencies, you know that attempting to document income or legal status can lead you down a “black hole” on healthcare.gov. Document processing has improved, but it continues to be a significant problem. The system loses documents, requires consumers to upload the same documents multiple times, and fails to adequately communicate with consumers what information is needed or where they are in the process. As a result thousands of consumers have unfairly lost subsidies or coverage all together. We’re hoping the process for special enrollment periods is smoother and more reliable, but from what we’ve seen so far, it may be a bumpy road.

Second, while submitting documents seems like a relatively simple task, this is an additional burden on consumers going through an often stressful life event who are trying to get or to change their health insurance coverage. Once married, it still takes time and effort to get a marriage certificate. Had a baby? Make sure you remember to submit and to send that application for a birth certificate. Lost your job and health insurance? Better hope your human resources department can help you. For many, like single parent households, a majority of them low-income, getting the required document will often require time and persistence.

In actuality, special enrollment periods are already underused. One national studyfound that fewer than 15 percent of uninsured consumers are enrolling through SEPs for which they qualify. Millions of individuals may be eligible for special enrollment periods, but not taking advantage of them when they have life events like moving, losing employer-sponsored coverage, getting married or having a baby. Rather than focus on the verification process, as others have noted, the key to increasing marketplace enrollment throughout the year may be more outreach and education about special enrollment eligibility.

Until then, since the administration has already changed its policy with SEP verification, let’s hope the way it’s implemented is as easy for consumers as possible. Let’s hope that there’s a way for consumers to attest in person, perhaps in the presence of an assister, of their life change to qualify for special enrollment periods, lessening the requirement to obtain other documentation. Also, let’s hope that the communication between consumers and the Marketplace is clear. When consumers call the Marketplace on the status of the document review, let’s hope consumers get the information they need to know where they are in the SEP eligibility process. As implementation details get worked out, let’s hope the administration listens to the concerns of consumers and advocates as much as they listen to those of insurers.