Buying a short-term health plan in Washington, DC
- DC regulations limit short-term plans to less than 365 days.
- New federal regulations also allow 364-day terms for short-term plans as of October 2018.
- DC’s Standing Advisory Board has recommended that the city council limit short-term plans to three months and prohibit renewal.
- At least six insurers offer short-term plans in DC.
Short-term plans limited to less than 365 days in DC
Prior to 2017, the DC Department of Insurance, Securities, and Banking (DISB) posted a memo clarifying that short-term health insurance plans had to last less than 365 days, and are not regulated by the ACA.
Starting in 2017, however, federal regulations (enacted by the Obama Administration in 2016) began to limit short-term health plans to no more than three months, and prohibited renewal. But the Trump Administration has relaxed those rules.
Because DC does not limit short-term plans, the Trump Administration’s new regulations apply in the District. Insurers will be allowed to offer short-term plans with initial terms up to 364 days and the option to renew for a total duration of up to 36 months.
In May 2018, DC’s Standing Advisory Board unanimously recommended that the DC City Council implement rules to limit short-term health insurance plans to three months in duration and prohibit renewals. But as of September 2018, the Council has not acted on that recommendation. Without legislative action to limit the duration of short-term plans, an Urban Institute analysis estimates that the expansion of short-term plans under the new federal rules will reduce the size of DC’s ACA-compliant market by 30.5 percent.
Short-term health insurance: DC regulations
DISB reviews rate filings for short-term plans, just as they review filings for ACA-compliant major medical plans. In July 2016, the following notice was posted on pending short-term rate filings, indicating that the filings were being rejected for the time being:
“It was decided just late yesterday afternoon that DISB WILL NO LONGER approve any STM policies until such time that the new federal regulation (that has a ` 3- month max. term coverage with no renewal allowed’ provision ) passes sometime next year (hopefully) —– ( see link site —– http://federalregister.gov/a/2016-13583) —– (this newly adopted DISB rule pertains to those STM policies that are sold to the DC general population only —- & excludes those that are sold as Student Policies with specific target market which can also be filed as a `Blanket Student Health Benefit TOI’ coverage type in SERFF ).” The new federal legislation has not been enacted yet.
That proposed federal regulation was finalized in late 2016, and took effect in 2017, limiting short-term plans to no more than three months in duration, nationwide. But those rules were rolled back as of October 2018, under the terms of the Trump Administration’s new rules.
Which insurers offer short-term plans in DC?
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.