The U.S. Department of Health and Human Services has added two additional special enrollment periods in recent weeks for the Affordable Care Act’s federal- and state-run public health insurance exchanges, but the National Association of Health Underwriters says the organization and its members want more.

See related: Why it’s not too late for employees to get on the exchanges

"Agents and brokers are the only group of marketplace-certified individuals who provide clients with support in utilizing their new health insurance coverage throughout the plan year and beyond the enrollment season,” NAHU CEO Janet Trautwein said in a statement Thursday that also introduced a list of recommendations to HHS for additional periods. “We welcome discussions with HHS about the potential SEP qualifying events we have proposed and additional ways agents and brokers could better assist marketplace consumers with enrollment and coverage service in the years to come."

NAHU’s suggestions for more opportunities to enroll consumers include: exemptions for expiring mini-med, short-term and temporary medical policies, renewal of non-calendar-year group health plans or mid-year changes in employer plan affordability, the creation of in-network geographic coverage deserts or significant mid-year network reduction, a mid-year income increase in states not expanding Medicaid or a mid-year income decrease, and judgments, decrees and domestic relations orders.

Trautwein added that the list comes directly from feedback given by agents and brokers out in the field working with consumers on the marketplaces.

One broker, who is also a NAHU member, cautions against too many exceptions, however.

“We need to strike the right balance between access and risk. With guaranteed issue and other consumer protections, entry into the individual marketplace shouldn’t be too loose or we’ll see that market blow up," says David C. Smith of Ebenconcepts in the Raleigh-Durham, N.C. area.

On May 2, the HHS issued guidance on two new special enrollment periods including for individuals who are on COBRA benefits or eligible for COBRA and those with individual policies renewing outside the open enrollment timeframe.

Previous HHS guidance has already stipulated that a special enrollment period of 60 days is triggered following life events including: a change in family status (i.e., marriage, birth of a child); loss of other health coverage; errors, misrepresentations, or inaction by an officer, employee, or agent of the exchange or HHS; obtaining the status of U.S. citizen; or exceptional circumstances, such as natural disasters like earthquakes or floods.

Smith says that perhaps some of NAHU's recommendations fit into the exceptional circumstances category. "But, I think we need to keep a tight lid on these exceptions just so people only buy when they need it versus when they should purchase it. They’ve got to have some responsibility too," he says.

Many group benefit agents and brokers have decided to expand their business model, or simply help those who come to them, with enrollment on exchanges throughout the country. As such, NAHU is advocating on behalf of such agents and brokers.

“NAHU members routinely work with individuals who had prior coverage that didn't need to be replaced during the open-enrollment period but now face events that will cause them to lose coverage or experience a coverage change before the beginning of the next open-enrollment period,” Trautwein’s statement also reads.

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