- Enrollments completed during the COVID-related enrollment window in 2021 will generally take effect the first of the following month.
- Enrollments completed during open enrollment will generally take effect January 1. But in states with extended open enrollment, a February or March effective date is possible.
- If you’re enrolling as a result of a qualifying event, the effective date rules vary depending on the qualifying event.
- If you enroll off-exchange, the same effective date rules are generally followed. Non-ACA-compliant coverage can be purchased with an immediate effective date, but medical underwriting will generally be used for these plans.
Q. If I enroll in the exchanges, will that coverage take effect immediately? What’s the earliest my coverage will take effect after I complete the enrollment process?
A. In most cases, your health insurance coverage will not take effect immediately. There are general effective date rules that apply each year during open enrollment and during special enrollment periods triggered by qualifying events, which are addressed below.
COVID-related enrollment period
The situation is different in 2021 due to the ongoing COVID pandemic and the need to give people access to the enhanced premium subsidies created by the American Rescue Plan.
The federal government has opened a COVID-related special enrollment period on HealthCare.gov (which can also be accessed via enhanced direct enrollment on various partner websites), which runs through August 15. All of the state-run exchanges have also announced COVID-related special enrollment periods, although they have varying deadlines and rules.
In virtually all cases, however, enrollments completed during the COVID-related special enrollment period will have coverage effective the first of the following month. And a qualifying event is not necessary in order to enroll during the COVID-related enrollment period, even though it’s outside of the normal open enrollment period (ie, a qualifying event would normally be necessary in order to enroll at this time in the year, but the rules are different in 2021).
In Maryland, retroactive effective dates are possible during the COVID-related enrollment period, depending on when a person completes the enrollment.
In nearly every state, if you enroll during open enrollment, your plan will take effect January 1 of the coming year. This is true regardless of whether you sign up on November 1 or December 15 or any day in between. But there are some states where open enrollment extends into January, giving enrollees the possibility of a February or March effective date instead.
In addition, if any insurers exit the market or terminate certain plans (replacing PPOs with HMOs, for example) at the end of the year, the people enrolled in those plans will be eligible for special enrollment periods. The special enrollment period, in that case, will run for 60 days before and 60 days after the loss of coverage.
People in this situation who pick a replacement plan before the end of December will have coverage effective January 1 (even if they enrolled after December 15). If they pick a replacement plan in the first 60 days of the new year, their new plan will take effect either the month after the enrollment is completed or the month after that, depending on the enrollment date. (If the enrollment is completed after the previous plan terminates, the 15th-of-the-month rule, described above, is applicable, but again, this will no longer apply on HealthCare.gov as of 2022; coverage will simply take effect the first of the month after the enrollment is completed.)
Special enrollment periods
Outside of open enrollment (ie, if you’re enrolling due to a qualifying event), the regular schedule in all but two states works like this (unless you’re enrolling due to loss of coverage, marriage, or adding a dependent; these scenarios are discussed below):
- If you enroll by the 15th of the month, your coverage will take effect the first of the following month.
- If you enroll between the 16th and the end of the month, your coverage will take effect the first of the second following month.
So an enrollment completed on May 9 would have a June 1 effective date, but an enrollment completed on May 17 would have a July 1 effective date. This will change on HealthCare.gov as of 2022, when new rules will take effect. People enrolling during special enrollment periods will be able to have coverage effective the first of the following month, regardless of the date they enroll.
But as noted above, the rules are different in 2021. The COVID-related enrollment period, which extends through August 15 in most states, allows people to enroll with coverage effective the first of the following month, regardless of the date they enroll. And unlike normal special enrollment periods, a qualifying event is not necessary during the COVID-related enrollment period (some state-run exchanges have only opened their COVID-related enrollment windows to people who are otherwise uninsured, but are likely to make that more flexible in the coming weeks in order to give current enrollees a chance to switch to a different plan and take advantage of the larger premium subsidies created by the American Rescue Plan).
Two states with different special enrollment period effective dates
There are two states – Massachusetts and Rhode Island – where the exchanges allow people to enroll as late as the 23rd of the month and still have a first-of-the-following month effective date. So May 17 enrollment in one of those states would result in a June 1 effective date (but a May 24 enrollment would result in a July 1 effective date).
Qualifying events with different effective date rules
If you’re enrolling during a special enrollment period triggered by a qualifying event, effective dates mostly follow the schedule outlined above. But if you get married, you’re eligible to get coverage effective the first of the following month, regardless of how late in the month you enroll (as noted above, that’s how effective dates work during the COVID-related enrollment period, and it’s also how effective date rules will work on HealthCare.gov for any qualifying event as of 2022). And if you have a baby, adopt a child, or receive a court order for medical child support, the coverage can be backdated to the date of the birth, adoption, or court order. CMS has confirmed that this is still available during the COVID-related enrollment period: A newborn or newly adopted child can be enrolled with a retroactive effective date, and SEP documentation does not need to be submitted if it’s during the COVID-related enrollment period and the family is using HealthCare.gov.
Loss of other coverage is a qualifying event that also allows for different effective date rules — if you enroll before your old plan ends. You can enroll up until the day your old plan ends and your new plan will take effect the first of the following month — so you won’t have any gap in coverage, assuming your old plan ends on the last day of the month (if your old plan ends mid-month, you will have a gap in coverage until the start of the following month; you could consider a short-term health insurance plan for this period, and if COBRA is an option, you could retroactively elect COBRA if a medical need were to arise before the new plan takes effect). If you wait and enroll during the 60 days after your old plan ended, your effective date will follow the normal rules described above (again, as of 2022 on HealthCare.gov, this will mean the coverage will take effect the first of the month after you enroll. And during the COVID-related enrollment window, coverage takes effect the first of the following month without the need for verification of a qualifying event).
Outside the exchanges, effective dates generally follow the same rules as inside the exchanges. If you’re enrolling in a non-ACA-compliant plan (like a short-term health plan), coverage can be effective as soon as the day after you enroll, but the insurer can use medical underwriting to determine your eligibility for coverage.
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.