"Presumably the Bulletin is intended to assist enrollees in states like Massachusetts, Oregon, Maryland, Nevada, and Hawaii, where technical problems have made it difficult or impossible for individuals to enroll in QHPs through the exchange on a timely basis. It could also, however, apply to the federal exchange. Each exchange must apparently decide whether or not to effectuate this policy.... If states have been assisting with cost sharing or with premiums prior to retroactive eligibility being determined, they must arrange for a refund with the QHP insurer. Exchanges may not discriminate between enrollees or insurers in applying retroactive coverage."  MORE >>