Coverage effective dates: Key takeways
- Enrollments completed during open enrollment will generally take effect January 1.
- 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: In most cases, 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 enroll during open enrollment, your plan will take effect January 1 of the coming year. But there are some states, discussed below, where open enrollment extends into January, giving enrollees the possibility of a February or March 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.
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.
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. 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 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.
COVID-19 special enrollment period effective date rules
To address the COVID-19 pandemic, most of the fully state-run exchanges opened special enrollment periods to allow people without health insurance to enroll in coverage. In some cases, retroactive coverage was available through these enrollment windows. That continues to be the case in Maryland, where the COVID-19 special enrollment period continues until mid-December 2020. Uninsured Maryland residents who enroll in the first half of each month will have coverage backdated to the first of the month.
Open enrollment for 2021 coverage
Open enrollment for 2021 coverage ends on December 15, 2020 in most states. During open enrollment (for people who don’t have a special enrollment period that overlaps with open enrollment), the first available effective date (even for people who sign up on November 1, 2020) is January 1, 2020. This is true regardless of when during open enrollment a person signs up; people who enroll on November 1 get the same effective date as people who enroll on December 15. And in almost all states, January 1 is the only available effective date.
But there some state-run exchanges – California, Colorado, Nevada, Pennsylvania, and Washington, DC – have extended open enrollment for 2021 health plans so that it will continue into January 2021. This means some enrollees in those states (ie, people who enroll after December 15, 2020) will have coverage effective in February or even March of 2021.
In addition, if any insurers exit the market or terminate certain plans (replacing PPOs with HMOs, for example) at the end of 2020, 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 2021, 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.
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