Coverage effective dates: Key takeways
- Enrollments completed during open enrollment will generally take effect January 1.
- In DC, NY, CA, CO, CT, and MA, open enrollment for 2020 continues into January so there are later effective dates available.
- If you’re enrolling as a result of a qualifying event, the effective date rules vary depending on the qualifying event.
- In states with extended open enrollment, effective dates for coverage will be effective in February or even March.
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: No, it will not take effect immediately. Your coverage effective date mostly depends on the date that you enroll, although there are some qualifying events that allow for effective dates that differ from the regular schedule.
In nearly every state, if you enrolled during open enrollment, your plan will take effect January 1 of the coming year. But there are some states, discussed below, where open enrollment has been extended into January, giving enrollees the possibility of a February effective date instead.
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.
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). Washington used to have a 23rd of the month deadline as well, but they changed that in 2017, and now use the same 15th of the month enrollment deadline that’s used in most other states.
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. 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.
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 last day of the month 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 was ended on the last day of the month. But if you wait and enroll during the 60 days after your old plan ended, your effective date will follow the normal rules described above.
Open enrollment for 2020 coverage
Open enrollment for 2020 coverage ended on December 15 in most states (plus a brief extension added at the end). During open enrollment, the first available effective date (even for people who signed up on November 1, 2019) is January 1, 2020. In almost all states, this is the only available effective date.
But there are six state-run exchanges – California, Colorado, Connecticut, Massachusetts, New York, and Washington, DC – where open enrollment will continue into January, which means some enrollees will have coverage effective in February or even March.
In addition, if any insurers exit the market or terminate certain plans (replacing PPOs with HMOs, for example) at the end of 2019, 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 enroll after December 15). If they pick a replacement plan in the first 60 days of 2020, 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.)
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.