What Are Idaho's Enhanced Short-Term Health Plans?

A Cross Between ACA-Compliant Plans and Traditional Short-Term Plans

Starting in 2020, two health insurance companies in Idaho—Blue Cross of Idaho and SelectHealth—began offering "enhanced" short-term health insurance plans. Although short-term health insurance plans are available in most states in the U.S., Idaho's enhanced short-term plans follow different rules and are a unique type of coverage.

The enhanced short-term plans can be thought of as a hybrid of traditional short-term health plans and Affordable Care Act-compliant major medical plans—they have some aspects of each type of coverage.

In 2019, Idaho enacted legislation (House Bill 275) that laid out the framework for the creation of the new enhanced short-term health plans. This came after the state had tried, in 2018, to start allowing insurers to sell "state-based plans" that would have skirted some of the Affordable Care Act's (ACA) requirements.

The federal government notified Idaho's governor and insurance commissioner that the "state-based plans" would not be allowed, but specifically suggested that the state's idea might be workable as short-term health plans, as the ACA does not apply to short-term plans and the federal government had recently relaxed the rules for short-term plans.

So insurance regulators and lawmakers in Idaho began work on the necessary legislation, which was enacted in the spring of 2019. Insurance companies were then free to start designing enhanced short-term plans; both Blue Cross of Idaho and SelectHealth have done so, and the state expects other insurers to follow suit.

Map of idaho made of pharmaceuticals.
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Idaho's Rules for Enhanced Short-Term Plans

Idaho's enhanced short-term plans are required to follow a variety of rules that don't apply to traditional short-term plans. Both types of coverage are available for purchase in Idaho, so the distinction is important (many of the short-term plans that people can buy in Idaho as of 2020 are not enhanced short-term plans).

Federal rules for traditional short-term plans are currently quite lenient, after being relaxed by the Trump administration in 2018: The plans can last for up to 364 days if they're non-renewable, and up to three years if they're renewable.

And they do not have to abide by any of the ACA's consumer protection requirements (i.e., coverage for pre-existing conditions, benefit amounts, guaranteed-issue rules, coverage of essential health benefits, etc.).

Idaho has its own rules for traditional short-term plans, which include a ban on renewals. So traditional short-term plans in Idaho cannot last more than a year, but they are not subject to the state's various rules that apply to normal health insurance plans.

But the state created an entirely separate set of rules for the new enhanced short-term plans, which are designed to be much more robust than traditional short-term plans, but with some flexibility that doesn't apply to ACA-compliant plans. Idaho's enhanced short-term plans:

Sellers Rule

Rule: Can only be sold by health insurance companies that also offer ACA-compliant plans through Your Health Idaho (the state's health insurance exchange), and the insurer must combine their enhanced short-term plans and ACA-compliant plans into a single risk pool.

As of 2021, there are three additional insurers that offer plans through the exchange but do not offer enhanced short-term plans; these insurers have the option to start offering enhanced short-term plans if they wish to do so, although the plans would have to be approved by state regulators before they could be sold.

Duration Rule

Rule: Are required to be renewable for up to a total duration of 36 months. A person can keep the plan for a shorter period than that, but the insurer has to allow renewability if the member wants it.

And if the enrollee wants to continue to have enhanced short-term coverage for longer than 36 months, the insurer has to allow them to re-enroll in a new policy without medical underwriting.

Waiting Period for Pre-Existing Conditions Rule

Rule: Can have a waiting period before pre-existing conditions are covered, as long as the plan is made available for purchase year-round. If the plan is only available during open enrollment, the insurer cannot impose a waiting period.

(As of 2020, both SelectHealth and Blue Cross of Idaho allow their enhanced short-term plans to be purchased year-round, which means that they can and do impose pre-existing condition waiting periods of up to a year, although it's shorter for people who had continuous coverage prior to enrolling in the enhanced short-term plan.)

Medical History Rule

Rule: Cannot reject applicants due to medical history. But the insurers can base premiums on medical history (and can impose a pre-existing condition waiting period if the plan is available for purchase year-round). Premiums cannot, however, be based on gender.

Benefits Rule

Rule: Must cover the ACA's essential health benefits (according to Idaho's benchmark plan) and must have benefit maximums of at least $1,000,000.

Transition Rule

Rule: Must allow a person whose enhanced short-term plan is ending (after 11+ months of coverage) to transition to any of the insurer's ACA-compliant plans, even if this occurs outside of the normal open enrollment period that applies to ACA-compliant plans.

Popularity of Enrollment

Blue Cross of Idaho started offering enhanced short-term plans for sale in the fall of 2019, with coverage effective January 1, 2020. SelectHealth began offering its version of the plans in early 2020.

Early demand exceeded expectations, and the plans have proven popular among people who need to buy their own health insurance in Idaho but who can't afford ACA-compliant coverage.

Most people who purchase coverage in the individual market are eligible for premium subsidies (in Idaho, these subsidies are provided via Your Health Idaho). But for people who don't qualify for subsidies, however, ACA-compliant coverage can be unaffordable, especially if the enrollee's income is just a little above the cutoff for subsidy eligibility.

As of mid-2020, the state reported that nearly 3,000 residents had enrolled in enhanced short-term plans. This is still far less than enrollment in ACA-compliant individual market plans; there are more than 72,000 people enrolled in ACA-compliant plans through Idaho's exchange, in addition to people who have off-exchange coverage.

Factors in Deciding on a Plan

Idaho's enhanced short-term plans are less expensive than full-price ACA-compliant plans, but generally more expensive than traditional short-term health plans.

A person who does not qualify for a premium subsidy through Your Health Idaho may find that an enhanced short-term plan is their best option, particularly if they're otherwise unable to afford a full-price plan.

These plans do have their drawbacks, and the protections they offer are not as iron-clad as those offered by ACA-compliant plans. But they're far more robust than many traditional short-term health plans, and certainly a better option than going without coverage altogether.

Although Blue Cross of Idaho and SelectHealth both offer enhanced short-term plans, they also both offer traditional short-term plans with term limits of no more than six months, and they also both offer ACA-compliant plans—so understanding the difference between these options is a big part of figuring out the best plan to meet your needs.

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Article Sources
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  1. Idaho Legislature. 2019 Legislation. House Bill 275. Enacted April 4, 2019.

  2. Verma, Seema. Department of Health and Human Services. Letter to Idaho Governor Butch Otter and Idaho Department of Insurance Director Dean Cameron. March 8, 2018.

  3. Idaho Office of the Governor (Brad Little). Gov. Little applauds federal court decision supporting Idaho health insurance option. July 20, 2020.

  4. Idaho Statute. Title 41, Chapter 52; Section 41-5214—Enhanced Short-Term Plans.

  5. Idaho Department of Insurance. Short-term, limited duration health insurance plans guidance.

  6. Idaho Statutes. Title 41 (Insurance) Chapter 52 (Individual Health Insurance Availability Act).

  7. Idaho Department of Insurance. 2019-2020 DOI Rulemaking Activity. Rules Governing Short-Term Health Insurance Coverage—Docket Number 18-0416-1901.

  8. Norris, Louise. healthinsurance.org. Idaho health insurance marketplace: history and news of the state’s exchange. October 5, 2020.

  9. SelectHealth. Idaho Enhanced Short-Term Plans.

  10. Blue Cross of Idaho. Access Plans for Individuals and Families.

  11. Tozzi, John. BenefitsPro. Idaho's 'enhanced short-term plans' a hit with consumers. January 14, 2020.

  12. Centers for Medicare and Medicaid Services. Early 2020 Effectuated Enrollment Snapshot. July 23, 2020.

  13. Blue Cross of Idaho Access Plans Brochure (2020) and SelectHealth Enhanced Short-Term Plans Brochure (2020).