Q. We have a health insurance policy through our state exchange. We’re moving this summer, but only about 50 miles away, and we’re staying in the same state. Is that a qualifying event that lets us switch to a different health plan, or would we have to be moving out of state to qualify for a special open enrollment?
A. It might be a qualifying event. It depends on whether the health plans available in your new area are the same ones available in your current area. In many states, health plan availability is regional, and not all QHPs are offered in all parts of the state.
Before we get into the specifics that normally apply, a reminder that enrollment is open in almost every state through at least August 15, 2021, due to the COVID pandemic and the American Rescue Plan‘s additional premium subsidies. During this special enrollment window, a qualifying event is not necessary. Uninsured residents can enroll in coverage, and in most states, current exchange enrollees can switch plans during this window even if they don’t have a qualifying event, without restrictions on metal level changes.
But here’s how the rules normally work, and how they’ll work again after the COVID/American Rescue Plan enrollment window ends:
Are different plans available in the new area?
If the health plans available to you after your move are the same as the ones available in your current area, your move will not be considered a qualifying event and you won’t qualify for a special open enrollment (SEP) window. But if the new area has different health plans available (even if your current plan is available in both areas), your move would count as a qualifying event and you’ll have 60 days to enroll in a new plan.
You can’t switch metal levels with this SEP
As a result of the market stabilization rule that was finalized in 2017, your ability to enroll in new plans in the new area would be restricted to plans at the same metal level as the plan you have now (or up or down one metal level, if there are no plans at your current metal level available in the new area). In other words, you can’t use a permanent move as an opportunity to drastically change your health insurance coverage.
Did you already have coverage in place before your move?
In February 2015, HHS finalized updated rules for some qualifying events. They issued additional guidelines for the permanent move SEP in May 2016. Starting in July 2016, the SEP was only available to people who already had minimum essential coverage for at least one of the 60 days prior to their move (with exceptions for people newly-released from incarceration, moving back to the US from abroad, or previously in the coverage gap in a state that has not expanded Medicaid).
Since you already have coverage through the exchange, this won’t be an issue for you. The purpose of the new regulation is to ensure that people cannot go without coverage and then move for the purpose of obtaining health insurance if and when they are in need of medical care.
You may or may not be able to sign up in advance of your move
The new regulations also make it permanently optional for exchanges to offer advance access to the SEP for a permanent move. Allowing people to enroll in a plan up to 60 days in advance of a move (with coverage effective the first of the month following the move) was already optional for exchanges, but exchanges were going to have to offer that option as of January 2017. The new regulations removed that deadline, so it continues to be optional for exchanges to allow applicants to report a permanent move in advance of the moving date.
There continues to be a SEP that extends for 60 days following the move, assuming the applicant had minimum essential coverage prior to the move. But exchanges can choose not to offer the SEP in advance of the move.
If your exchange allows you to make a plan selection from among the QHPs available in your new area on or before the day of your move, your effective date will be the first of the month following the move. If you make your plan selection during the 60 days following your move, your coverage effective date will follow the normal effective date rules in your state’s exchange (in all but two states (Rhode Island and Massachusetts), plan selections made by the 15th of the month have a 1st of the following month effective date; HealthCare.gov will eliminate the 15th-of-the-month deadline in 2022, allowing plan selections to simply take effect the first of the following month).
The exchanges are permitted to backdate the effective date to the date of your move, but they are not required to. So you should expect that your new plan won’t be effective until the first of the month following your move, even if the exchange allows you to enroll in a new plan prior to the date of your move. But as long as you’re current with your premiums for your original plan, it will continue to provide emergency care in your new area for the remainder of the month of your move, even if doesn’t have network providers in your new area.
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.