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Grandmothering Extended Into 2022 for Pre-ACA Plans

Applies to: Small Employer market (4Q21 renewals)

Horizon Blue Cross Blue Shield of New Jersey will once again enable Small Employer group customers that renew between October 1 and December 31, 2021, and offer health plans that preceded the Affordable Care Act (“pre-ACA plans”), to renew within those pre-ACA plans. With the fourth quarter representing our highest volume of renewing membership, our decision to grandmother pre-ACA plans will facilitate a smooth renewal process.

If a group leaves its pre-ACA plan, it may move to an ACA-compliant policy with stand-alone pediatric dental (SAPD) coverage if it meets the eligibility requirements. Popular ACA-compliant options include our OMNIASM Health Plans.

As we get closer to fourth quarter 2021, Horizon BCBSNJ will communicate the important details and dates for the renewal process. Until then, here’s what you can expect: 

Broker Communications

  • Pre-ACA and ACA renewals for October, November and December will be available to the Broker of Record via the FTP secure site. An email will be sent when renewals are available.
  • The renewal release schedule is as follows:
    • October renewals: by July 31
    • November renewals: by August 31
    • December renewals: by September 30

Group Communications

  • Pre-ACA renewals for October, November and December will include a renewal for the pre-ACA plan, an offer for a recommended ACA plan, and a CMS Model Notice.
  • ACA renewals for October, November and December will include the recommended ACA plan.
  • The renewal release schedule is as follows:
    • October renewals: by July 31
    • November renewals: by August 31
    • December renewals: by September 30

Groups with pre-ACA plans will automatically renew as is within the existing pre-ACA plans unless they actively select an ACA plan.

Pre-ACA to ACA Plan Conversions

All groups converting from a pre-ACA plan to an ACA plan are required to send in the conversion form, new certification paperwork, including applicable tax documentation as noted below, and waivers. Please submit the ACA conversion through Broker Online Services.

Mandatory Tax Documentation for Groups with Two to Five or 45+ Eligible Employees

These requirements apply to all pre-ACA to ACA conversions regardless of whether they previously sent their certification to Horizon BCBSNJ and were advised by Horizon BCBSNJ Small Group Certification they could renew as is.

Group Structure

Form

Additional Documentation

Single Owner/
Sole Proprietor

Schedule C

Q3 2021 WR-30 for employees

Partnership
(must be 100% ownership)

K-1(s)

Q3 2021 WR-30 for employees

Corporate Entities
(C- and S-corps)

Schedule G

Q3 2021 WR-30 for employees

All Groups

 

NJ State WR-30:
Most recent completed quarter for all employees1

WR-30 = Quarterly Wage Report
¹Effective October 1, 2021 and after, third quarter WR-30s will be required for fourth quarter 2021 conversions.

Groups of six to 44 eligible employees do not need to submit tax documents. Instead, these groups need to submit the Certification with Conversion form and waivers.

If a group accepts its existing pre-ACA or ACA plan renewal, no paperwork is necessary. Conversion paperwork is only required if a group converts to a different ACA plan alternative or if it moves from a pre-ACA plan to an ACA plan.

The conversion deadline for renewing groups or off-anniversary conversions is five business days prior to renewal date. Complete paperwork must be submitted in a timely manner. Incomplete paperwork may cause the group to lose their requested conversion date.

Conversion paperwork must be emailed to Conversion@HorizonBlue.com.

Certification Paperwork Submission

New certification paperwork, including waivers and tax documents as outlined above, is required with the conversion paperwork for groups of two to five and 45 or more eligible employees when converting from pre-ACA to ACA plans. This helps us ensure that husband/wife, sole proprietor and owner-only-enrolled groups are renewing as is in their pre-ACA plans and are not converting to an ACA plan; these groups are not eligible for ACA plans.

Horizon BCBSNJ sends certification paperwork at least 120 days prior to a group’s renewal. Groups are instructed to complete and return the paperwork to Horizon BCBSNJ within 15 days of receipt. At that time, the group will not have received its renewal to decide to renew into the existing pre-ACA plan or move to an ACA plan.

Published on: May 24, 2021, 09:14 a.m. ET
Last updated on: June 14, 2021, 16:50 p.m. ET