Along with the headline yesterday that nearly 10 million consumers paid their premiums and had an active marketplace health insurance policy as of the end of June 2015, there was very disappointing news. The federally facilitated marketplace (FFM) already terminated overage for about 423,000 people with 2015 coverage who had immigration or citizenship status data matching issues.* This means that these individuals lost coverage because the FFM could not electronically verify or did not receive (by online upload or mail) sufficient documentation of their citizenship or immigration status.

Integrity in public programs is critical. And making sure that individuals who are enrolled in marketplace plans and receiving federal subsidies have an immigration or citizenship status that qualifies them for this coverage and subsidies makes sense.  But, that is not the full story here.

These individuals did not all lose coverage because they are not citizens or are not lawfully present. Some, and likely many of the 423,000, lost coverage because the marketplace’s system and processes make it difficult to connect the dots and verify this information. There are several points where the system and processes break down:

• When individuals’ apply for coverage online, HealthCare.gov cannot recognize immigration-related document numbers or cannot verify immigration status electronically with the Department of Homeland Security (and in some cases citizenship status with the Social Security Administration).
• The notices provided by the marketplace are sent by mail in English and Spanish only, and the translated taglines in the notices (provided in 15 languages) are boilerplate and do not indicate with specificity that action is needed.
• If already uploaded or mailed-in documentation was not sufficient and additional documentation was needed, the FFM had no way to communicate this information with policyholders. Instead of a an explanation about why the documents they submitted were not adequate and what was needed, individuals just received a generic notice to submit documentation, so some continued to submit the same documentation as before in a vicious cycle to no effect.

As a result, 423,000 people lost coverage they applied for and thought they were enrolled in for the year. Some of these individuals—because they do not understand their termination notice in English—may not even know they are no longer enrolled until they go to a doctor’s appointment or a hospital. These people may never come back to HealthCare.gov to enroll, and they may share their frustrating story with others who may never apply.

Advocates have been urging HHS to improve the enrollment system and processes for immigrant families since problems arose in the first open enrollment period. Some areas have improved, but in the last few months, we at CCF have spent a lot of time listening to consumer assisters about the application and enrollment experiences of people in immigrant households in particular. We are working on a report with that will include more thorough and specific recommendations, but in the meantime, we have already identified some improvements HHS should start working toward to resolve these data-matching problems:

• Test the system rigorously with knowledgeable users to identify why inputting and verifying immigration numbers electronically breaks down and address the causes of this problem.
• Take additional steps to resolve data-matching problems before putting individuals in an inconsistency period.
• Improve communication with individuals with data-matching issues. This means improving both the content and specificity of the notices and translated taglines and also providing translated notices based on HHS’s LEP guidance. It also means providing more types of communication – like phone or text messages – and not relying only on paper mail to communicate.

With the third open enrollment period starting in only a few weeks, HHS needs to make these fixes a priority and act quickly to prevent this same cycle of problems from arising next year.

*Note: If a consumer believes they had the appropriate documentation but their FFM enrollment was terminated based on a citizenship/ immigration status data matching issue, the individual can submit his or her documentation to resolve the issue and regain enrollment in the Marketplace through a Special Enrollment period.