With the premium billing move back to the carriers, what would the process be in members are sending payments to the state for PY26 instead of the carriers?
The specifics are being determined and details will be provided in early 2025. BeWell will submit the payment to the carrier.
What is the impact to the 820 file process with this migration? While it’s obvious that we would receive the premium payment since that would move to paying the carriers directly but that is only 1 of the many we receive. What about format, timing, naming conventions, companion guide etc.
For Plan Year 2026 coverage and beyond, 820 files for APTC payments will only be sent to issuers from CMS following the standard monthly.
What about the 820 files that NFP would send for state subsidy payments? Who would be sending those in future state?
BeWell, Health Care Authority and GetInsured are reviewing the current process for the state subsidies. We expect changes and will provide more information as those changes are finalized.
If members are in grace period during renewal time with the states current premium process will those members be passively renewed? If the members are passively renewed how will non payment terminations work if they term for non payment of 2025 premiums?
Yes, members who are actively enrolled at the time of renewal will continue to be renewed, even if they have outstanding payments due and/or are in a grace period. If members are passively renewed, and subsequently termed for non payment, you will receive a non payment term for the applicable month in PY2025. You will not receive a cancel transaction for the PY2026 passive renewal.
Are carriers required to add the BeWell logo to their notifications (invoices, late notices, etc.)?
No, carriers are not required to include the BeWell logo on billing notifications.
Are there any state requirements for invoices and late notices or can carriers use their exisiting templates?
There are no BeWell requirements for invoices or late notices; however, carriers must adhere to the policies stated in N.M. Admin. Code § 13.10.23.9 – TERMINATION OF COVERAGE regarding non-payment termination.
For retroactive terminations, how will the refund be handled for members who paid premiums through BeWellnm?
BeWell will process refunds for payments related to 2025 coverage, through February 2026. BeWell will not process any refunds for 2026 coverage because the Carriers are managing the premium billing.
Members with a credit balance at the end of 2025, will receive a refund directly from BeWell.
What is the grace period for binder payment and subsequent payments? Also, what past due notifications are currently sent?
We do not have a grace period for binder payment. Subsequent payments are standard CMS grace periods of 30 days without APTC or 90 days with APTC. Check the carrier resource for samples of current notifications.
Will there be any new letters, or changes to existing letter templates? Also, which letters will be handled through the exchange, and which are expected to come from Issuers starting PY2026?
Other than the transition of the premium billing functionality, there will not be any change in the management of notifications (exchange v carrier). We have posted samples of the current premium billing notices on the carrier resource page.
Medicaid Transition Subsidy - NM HIX is not deducting the subsidy from the total responsibility amount on the 834. Should we expect the 820 D along with the enrollment to auto effectuate the case?
There will be an indicator on the 834 that lets the carrier know there is MTPR eligibility, and that the enrollment should be auto effectuated. Separate reporting will replace the 820D.
As there will not be a grace period for binder payment, does this mean that if payment is not received before the effective date, that the policy will be cancelled for non-pay, or would issuers follow FFM rules? For FFM, if there is a retro add transaction, the binder payment expected is up to the current month. Example: Current date is 2/1/2026 and a new enrollment comes in with a retro effective date 1/1/2026 , binder payment collected for FFM = January+February payment. Is this expected, or would Jan Payment satisfy binder for effectuation?
BeWell currently requires binder payment by the due date, which is the last day of the month before the coverage effective date, or at least seven days from the date enrollment ia submitted. For example, enrollment submitted on the 31st, binder payment would be accepted through the 7th of the next month. While grace periods are not allowed for binder payments, we recognize binder payment due dates may vary, and we are open to the FFM approach.
For the retro add transaction, Payment would be required for both the retroactive and current months. However, if a member enrolls for the current or future month, submits payment for that month, and subsequently adjusts the effective date to a prior month, they will be considered late since they were effectuated and would not be canceled. A grace period would then be triggered.
If members try to overpay for PY 2025 on the BeWell portal, how will BeWell handle that? At a certain point, will you limit the member to only pay the "total owed" for 2025?
The portal will remain open for payments through February 2026. Members who have overpaid for 2025 coverage will receive a refund directly from BeWell. Payments received by BeWell for 2026 coverage will be forwarded to the issuer via ACH, with member detail provided for each submission.
If there is another policy ID effective after a termination date, and the case was reinstated, how would we put the subsequent policy ID back on the case?
The new policy ID would need to be cancelled and the old policy ID reinstated. This would be taken care of via ticketing since Carriers are unable to send terminations or cancellations unless they are for nonpayment.
Will the SOPA template continue to be used? If it will not be used, how will issuers provide the plan data for the SOPA CSRs? In preparation for the May testing, will issuers need to create a different document in order to validate the SOPA CSRs?
There will be a new SOPA template that we anticipate will be very similar. More details will be shared very soon.
If a case does not have APTC subsidy, but has State Subsidy, what should their grace period be? 30 - 90 days, and what would the effective termination date be?
90 days
For NON-APTC cases what would be the grace period timeline. 30 or 31 days?
30 days/End of month
Beyond Feb 2026, how will beWell handle PY 2025 refunds to members who need legitimate refunds? (Some legit refunds could develop for a PY 2025 policy after Feb '26.)
Carriers will be responsible for processing refunds for PY 2025 after Feb 2026. As BeWell discontinues 820 production, the normal recoupment process for overpayments related to retroactive enrollment changes/terms for PY 2025 will no longer apply, i.e., carriers will have received the payment but will not receive a payment reversal. See examples below –
Ex – PY 2025 Carrier Refund
- Member pays for Nov 2025
- Payment is sent to the carrier on the Dec 2, 2025 820
- Member terms on Mar 10, 2026, retroactive to Nov 30, 2025
- Payment reversal for Dec 2025 is not sent to the carrier
- Carrier will refund the member for the Dec 2025 overpayment
Ex – PY 2025 BeWell Refund
- Member pays for Nov 2025
- Payment is sent to the carrier on the Dec 2, 2025 820
- Member terms on Feb 10, 2026 retroactive to Nov 30, 2025
- Payment reversal for Dec 2025 is sent to the carrier on the Mar 2, 2026 820
- BeWell will refund the member for the Dec 2025 overpayment
