MACRA guidelines only grant D & G to those who become eligible in 2020+. States and Carriers have the option of being more generous but it is not required, so they aren't "avoiding" anything....I just don't know how they have avoided MACRA guidelines.
Now you got it! States and Carriers have the option of being more generous and let older benes have G and/or N. For carriers, it's possible for older GI benes to have G in some states but not others.Seems to be arbitrary from carrier to carrier and state by state.
They do need to be consistent if it's the same carrier, same state, all in 2020, and all with the same plan letter.I have submitted 3 GI apps this year, all for folks on Medicare A & B prior to 1/1/2020. All submitted to the same carrier. Two approved, one denied.
UHC lists their GI rules for Georgia on page 23 of this application package. If you could find a similar document for your carrier and compare it to what they are actually doing, it would be a start.
2020 UHC Georgia Medigap: https://www.aarpsupplementalhealth.com/content/dam/EAP/GA_AARP_Med_Supp_Enrollment_Kit_C.pdf
For those who may not know, HD-F has always been GI since it's an F. HD-G is now GI for certain enrollees because it's a G. When CMS refers to F, they mean both versions unless they state otherwise. The same now applies to G.
"Section 12. Guaranteed Issue for Eligible Persons
E. Products to Which Eligible Persons Are Entitled. The Medicare supplement policy to which eligible persons are entitled under:
(1) Section 12B(1), (2), (3) and (4) is a Medicare supplement policy which has a benefit package classified as Plan A, B, C, F (including F with a high deductible), K or L offered by any issuer."
Source (from 2009): Medicare Program; Recognition of NAIC Model Standards for Regulation of Medicare Supplemental Insurance
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