[Updated March 11, 2015]
If you’ve been stressing out about the end of Obamacare’s open enrollment period – and a possible Obamacare penalty for missing the enrollment deadline – you may have gotten some welcome “wiggle room” from the federal government and several state exchanges.
Exchanges in every state designated deadline extensions for consumers who had started to enroll but were unable to complete their application before the February 15 deadline. But on February 20, the federal government announced a special enrollment period – from March 15 to April 30 – for people in 37 states who have found out (or will find out) that they’ll owe a penalty for 2014 when they file their tax returns.
Who gets the extension?
In order to be eligible for the special enrollment period, you must:
- not already have an existing exchange plan for 2015. (Plan changes will not be permitted during this special enrollment period.)
- attest that you paid the 2014 penalty when you filed your taxes, AND that you didn’t know about the penalty until you filed your 2014 tax return [edit, March 11: CMS has clarified that you just have to be subject to the penalty for 2014 in order to qualify for the special enrollment period – even if you haven’t yet filed your taxes, and/or haven’t yet paid the penalty, you can enroll during the special enrollment period as soon as you become aware of the penalty for being uninsured and the fact that you owe the penalty for 2014].
This special open enrollment period ends on April 30 at 11:59 p.m. Eastern Time.
- Enrollments submitted on March 15 will have coverage effective April 1.
- Enrollments submitted between March 16 and April 15 will have coverage effective May 1.
- Enrollments submitted between April 16 and April 30 will have coverage effective June 1.
Prorated penalty possible
A prorated penalty for not having coverage in 2015 will still apply to people who have a gap in coverage of three or more months in 2015. If you enroll on March 15, you’ll have coverage effective April 1, but you would still be subject to a prorated 2015 penalty for the first three months of 2015 (assuming you didn’t have coverage for any days during the first three months, and assuming you don’t qualify for any of the other penalty exemptions). If you enroll between March 16 and April 15, you’ll have coverage May 1 (and be subject to a prorated penalty for four months), and if you enroll between April 16 and April 30, you’ll have coverage June 1 (and be subject to a prorated penalty for five months). But because of this special enrollment period, you’ll be able to avoid paying a penalty for the full year.
47 states and DC offering tax season extension
The special enrollment period that CMS created is only valid in the 37 states that use the federally facilitated marketplace. But prior to the CMS announcement, three state-run exchanges (Washington, Minnesota, and Vermont) had already implemented similar special enrollment periods.
On February 23, Connecticut announced that a one-month special enrollment period would be available for people who didn’t realize they would owe a penalty for being uninsured in 2014. On March 3, Access Health CT announced that the special enrollment period would run from April 1 to April 30.
On February 24, kynect (Kentucky‘s exchange) announced a tax season special enrollment period that will run from March 2 to April 30, for people who were previously unaware of the ACA’s individual mandate penalty.
On February 25, Maryland Health Connection announced a tax season special enrollment period that will run from March 15 to April 30, for people who pay a penalty for being uninsured, and who attest that they didn’t know about the penalty prior to filing their taxes after February 15.
On February 26, Hawaii Health Connector confirmed by email that they are offering a special enrollment period for people who learn about the penalty when they file their taxes. It will run from March 15 to April 30.
On March 3, HealthSource RI announced that there will be a tax season special enrollment period in Rhode Island, running from March 15 to April 30.
On March 9, DC Health Link confirmed via email that they will offer a tax season special enrollment period for District of Columbia residents, from March 15 to April 30 (press release). The eligibility requirements are the same as Healthcare.gov is using.
As of March 9, the tax season special enrollment periods apply to people in 48 states:
- the 37 that use Healthcare.gov
- New York
- Rhode Island
No special enrollment period – three states:
- Massachusetts Health Connector said early on that it was unlikely they would offer a tax season special enrollment period, because the state has had an individual mandate with tax penalties for several years already. And on March 11, they confirmed that there will not be a tax season special enrollment period.
- On March 3, Your Health Idaho confirmed that they are not going to be issuing a special enrollment period for people who owe a penalty for being uninsured in 2014. The open enrollment extension in Idaho ended on February 21, and people there will need to have a special enrollment period triggered by a qualifying event in order to purchase 2015 coverage at this point.
- Connect for Health Colorado confirmed March 10 that they will not have a special enrollment period for people who find out that they owe a penalty for not having coverage in 2014. They gave a variety of reasons for the decision, including the cost of additional staffing (both at the exchange and for carriers, including off-exchange carriers, which are required by Colorado statute to follow the same enrollment periods as the exchange), and the fact that it wouldn’t be possible to enforce the requirement that the special enrollment period only apply to people who had to pay the penalty for being uninsured in 2014.