08. When does eligibility for government-sponsored coverage affect ConnectorCare?

Eligibility for the following types of government-sponsored programs counts as Minimum Essential Coverage (MEC) and disqualifies someone from eligibility for ConnectorCare:

• Medicare Part A.  

Eligibility for premium-free Medicare Part A.  

• A person enrolled in Medicare Part A or Medicare Advantage or eligible for premium-free Part A is not eligible for ConnectorCare. 

EXCEPTIONS:

• Individuals age 65 and over who are eligible for but not enrolled in Medicare who would be charged a premium for Part A are not considered eligible for MEC, and may qualify for ConnectorCare.  
• Individuals potentially eligible for Medicare solely based on End Stage Renal Disease (ESRD) who have not applied for Medicare and been found eligible may qualify for ConnectorCare.

IRS Notice 2013-41 (June 26, 2013)

• ​The current March 2019 application form asks if individuals are enrolled in Medicare or eligible for premium-free Part A. If the answer is yes or if data sources show enrollment in Medicare Part A or Medicare Advantage, the individual will not be eligible for ConnectorCare. 
• After an eligible individual enrolls in ConnectorCare, the Connector conducts periodic data matches with Medicare during the year. An individual who later enrolls in Medicare Part A or Medicare Advantage will be notified that he or she is no longer eligible for ConnectorCare. Generally, insurance carriers cannot sell duplicate coverage to Medicare beneficiaries; however, a beneficiary who loses ConnectorCare can remain enrolled in the same QHP for the balance of the year with no subsidy. (The Connector does not offer Medicare Supplement plans).

Advocacy Reminder:

If people do not enroll in Medicare Part B during their initial enrollment period or certain special enrollment periods, they may face late enrollment penalties that increase the amount of their Part B premiums and may not be able to enroll in Medicare until later in the year. Being enrolled in a plan obtained through a Marketplace/Exchange, like the Health Connector, does not exempt individuals from these disadvantages the way that being enrolled in employer-sponsored insurance may.  In recent years, Medicare has given individuals enrolled in the Marketplace an opportunity to avoid the disadvantages of delaying enrollment in Part B. This relief extends to those who could have enrolled in Medicare Part B but did not do so during their Medicare Initial Enrollment Period or Part B SEP for the working aged or disabled, and currently are or were enrolled in coverage through the Marketplace during certain dates from 2013 to Sept. 30, 2019.    See,  https://www.cms.gov/Medicare/Eligibility-and-Enrollment/Medicare-andthe-Marketplace/Downloads/SHIP-and-Navigators-Fact-Sheet-10-102018.pdf  Individuals can obtain more information about this assistance and about making the transition from ConnectorCare to Medicare from local SHINE counselors listed in the Resource section.

• Medicaid and the Children’s Health Insurance Program (CHIP)
  • ​​Medicaid and CHIP are both called MassHealth and eligibility for any type of MassHealth, other than MassHealth Limited (which only covers emergency services), counts as MEC.
  • The Children’s Medical Security Program (CMSP) and the Health Safety Net, like MassHealth Limited are not considered MEC.
  • There is a common application system for MassHealth (Medicaid and CHIP) and for ConnectorCare. An applicant who is found eligible for any kind of MassHealth except Limited will not be eligible for ConnectorCare. 

However, if an individual is initially eligible for ConnectorCare and is later found eligible for MassHealth, including a retroactive eligibility determination, the MEC disqualification will begin no earlier than the first day of the month beginning after the date of the MassHealth eligibility notice. 

• This is one of several situations where individual may have overlapping MassHealth and ConnectorCare without it being considered an excess payment of APTCs by the IRS. This will be important during the annual reconciliation process for advance premium tax credits discussed below in the Q & A 30. 
• TRICARE. 

Eligibility for medical coverage under TRICARE, 10 USC 55, for active duty service members and their families is counted as MEC. Certain limited benefit TRICARE coverage is not considered MEC.

• Veterans programs. 
  • The Veteran’s Administration health system under 38 USC 1710 and 1705 is available to most but not all veterans. Veterans enrolled in the VA health system have MEC. However, veterans who are not eligible for the VA health system, as well as those who are eligible, but choose not to enroll, are not counted as eligible for MEC, and may be eligible for premium tax credits and ConnectorCare. 
  • The family members of veterans are generally not eligible for VA health benefits, but family members of certain veterans may be eligible for the VA Civilian Health and Medical Program (CHAMPVA) or for the spina bifida health care program. CHAMPVA and the spina bifida program both count as MEC.

• Peace Corp program. 

Eligibility for the health plans for Peace Corps volunteers under the law at 22 USC sections 2504(e) is counted as MEC.

26 CFR 1.36B-2(c) (2) Government-sponsored MEC; IRS Publication 974, Premium Tax Credits (2018).

A note on age: There is no upper or lower age limit for ConnectorCare, but most people under 19 or age 65 and older do not qualify because they are eligible for government-sponsored MEC. Children and youth under age 19 who are US citizens or lawfully present non-citizens with family income not over 300% FPL generally qualify for MassHealth, and most individuals age 65 or older qualify for Premium-Free Medicare Part A.