Q. If I sign up for a Bronze plan during open enrollment, can I bump my coverage up to a higher level several months later if I find out that I need surgery?
A. In a normal year, no, but 2021 is not a normal year. Under the regular rules, you can only make changes to your plan during open enrollment or during a special enrollment window triggered by a qualifying event — and a change in health status is not a qualifying event.
But in 2021, there’s a COVID-related enrollment window that continues through August 15 in most states. And the American Rescue Plan has enhanced premium subsidies for 2021 and 2022, and made robust coverage available at no cost for people receiving unemployment compensation in 2021.
A qualifying event is not required in order to use the COVID-related enrollment window, and coverage will generally take effect the first of the month following enrollment. In every state, the COVID-related enrollment window can be used by uninsured residents who would like to enroll in a plan through the marketplace. And in most states, it can also be used by people who already have coverage and would like to switch to a different plan — for any reason at all. This will typically be due to the enhanced benefits provided by the American Rescue Plan, but it’s also an opportunity to switch to a different plan due to a change in medical needs, making 2021 unique in terms of the extended access to enrollment and plan changes.
HealthCare.gov, which is used in 36 states, is allowing maximum flexibility during the COVID-related enrollment period, letting people switch plans or newly enroll. Some of the state-run exchanges are taking a similar approach, but some are more restrictive, at least for the time being, and are only allowing uninsured residents to enroll without a qualifying event. They may take a less restrictive approach as time goes on, however, and as they get the enhanced premium subsidy information available to consumers on their enrollment platforms.
After August 15, 2021, the normal rules will once again apply: Plan changes will only be possible during open enrollment and special enrollment periods triggered by a qualifying event. These rules apply both on and off-exchange. So regardless of whether you buy your health insurance plan through the exchange or outside the exchange, you won’t have an opportunity to switch to a different plan until the following year (during open enrollment) unless you experience a qualifying event.
And even with a qualifying event, rules that HHS finalized in 2017 limit the ability to switch to a plan at a different metal level outside of open enrollment.