As Consumers Seek Insurance Coverage During Pandemic, United Hospital Fund Study Outlines Need to Upgrade NY’s “Off-Exchange” Market

Thursday, April 23, 2020

NEW YORK, NY—April 23, 2020—As consumers seek to replace lost job-based health insurance coverage or find new plans during the pandemic, a report released today by United Hospital Fund recommends a series of upgrades for New York’s “off-exchange” market for individuals, including the elimination of enrollment barriers for immigrants who are not permitted to get coverage through the NY State of Health (NYSOH) marketplace.

When the Affordable Care Act (ACA) was implemented in 2014, New York opted to create its own insurance marketplace, NYSOH—a one-stop shop for all public programs and ACA premium subsidies for eligible families. But it also preserved a second market segment for New York residents who prefer to purchase coverage directly from an insurer, and for undocumented immigrants who are ineligible to purchase through the marketplace. There are very limited tools available, however, to help individuals shop for off-exchange coverage, and outdated administrative requirements effectively bar undocumented New Yorkers from applying for coverage, even without any government financial support.

The report, New York’s “Other” Individual Market Needs an Update, recommends a number of common-sense improvements for the off-exchange market, including:

  • Replacing current requirements for Social Security numbers on health coverage applications with other kinds of documents, such as individual taxpayer identification numbers, tax and utility bills, or residential leases
  • Reviving a pre-ACA online guide for individual commercial coverage with basic information by county about participating off-exchange health plans, available products, health plan websites, toll-free numbers, retail locations, and available non-English language services
  • Increasing the awareness of coverage and benefit options, including child-only, dental, and vision coverage
  • Sending a strong message that off-exchange coverage is available to all New York State residents living in a health plan’s service area, not just those who meet ACA “lawfully present” standards for coverage through the NYSOH marketplace.

“Undocumented New Yorkers made up about a third of New York’s uninsured population before the pandemic struck, and most have incomes that make them ineligible for the limited programs available, such as Emergency Medicaid,” said Peter Newell, director of UHF’s Health Insurance Project and the author of the report. “Given the rapid spread of coronavirus infection and the significant costs of treating the disease, on top of the Trump Administration’s immigration policies, some families might be interested in enrolling in off-exchange coverage now, despite the high cost of unsubsidized coverage.”

He added, “New York moved quickly to roll back Medicaid eligibility provisions that might lead to involuntary disenrollment and to reopen the NYSOH marketplace for business during the pandemic. Eliminating off-exchange enrollment barriers seems like a logical next step.”

The full report can be downloaded free of charge here, and was supported by a grant from the New York Community Trust.


About United Hospital Fund

United Hospital Fund works to build a more effective health care system for every New Yorker. An independent, nonprofit organization, we analyze public policy to inform decision-makers, find common ground among diverse stakeholders, and develop and support innovative programs that improve the quality, accessibility, affordability, and experience of patient care. For more on our initiatives and programs please visit our website at and follow us on Twitter.

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