Qualifying events can allow you to purchase health insurance outside of open enrollment

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What are the ACA’s enrollment periods and when can I enroll outside of the open enrollment period?

Q: What are the Affordable Care Act enrollment periods and when can I enroll outside of the open enrollment period?

A: Open enrollment for 2018 will begin on November 1, 2017, and end on December 15, 2017 in all states that use HealthCare.gov. This applies both on and off-exchange. State-run exchanges have been encouraged to follow the same schedule, although HHS has acknowledged that state-run exchanges might run into technical difficulties since the open enrollment schedule was changed late in the game, in April 2017.

Colorado has already announced that their open enrollment will run from November 1, 2017 through January 12, 2018. Other state-run exchanges might follow suit with open enrollment periods that extend past December 15.

In states where open enrollment ends December 15, all plans will be effective January 1. In Colorado, enrollees who sign up in late December or early January will have coverage effective February 1.

Schedule for 2018 coverage changed in April 2017

In the Benefit and Payment Parameters for 2017, finalized in December 2016, HHS confirmed that open enrollment for 2018 coverage would run from November 1, 2017 through January 31, 2018 (the same November – January schedule that was used for 2016 and 2017).

But in April 2017, HHS (now headed by Secretary Tom Price, under the Trump Administration) finalized market stabilization regulations that include a switch to a shorter open enrollment period in the fall of 2017.

Open enrollment was already slated to switch to the shorter window beginning in the fall of 2018, for coverage effective in 2019 and beyond. The market stabilization regulations just moved up the schedule by one year, starting the shorter open enrollment period in the fall of 2017 instead of the fall of 2018.

Special enrollment periods

Regardless of whether you purchase insurance through the exchange or off-exchange, the annual open enrollment window applies. Nevada is an exception – coverage is available there outside the exchange year-round, albeit without subsidies and with a 90-day waiting period before coverage becomes effective. But in the rest of the country, you cannot enroll outside of open enrollment unless you have a qualifying event, such as:

Starting in 2016, Healthcare.gov began requiring proof of eligibility for the most common qualifying events, and the market stabilization regulations that HHS finalized in April 2017 require all applicants to provide proof of their qualifying events in order to enroll in a plan outside of open enrollment.

Some state-based exchanges were already requiring proof of qualifying events, and health insurance carriers also generally require proof of eligibility when people enroll off-exchange during a special enrollment period. If you experience a qualifying event and wish to enroll in a plan during your special enrollment period, be prepared to provide documentation of the qualifying event.

Native Americans and Alaska Natives can enroll year-round.  Applicants who are eligible for Medicaid can also enroll year-round.

Limited enrollment windows are normal and necessary when coverage doesn’t depend on your medical history

We frequently see people lamenting the fact that there’s a limited window in which to purchase coverage, but there are a couple points to keep in mind:

  • Limited open enrollment periods have long been the norm for employer-sponsored health insurance, which is where most non-elderly Americans get their coverage (you can’t just enroll in your employer’s plan anytime you like; you have to wait for open enrollment, unless you have a qualifying event).
  • Medicare also has limited annual open enrollment periods.
  • The individual health insurance market used to allow people to purchase coverage any time they wanted. But the insurance company would ask a long list of medical history questions, and would decline applications from people with serious pre-existing conditions. That’s no longer the case, so the limited enrollment window is necessary to prevent people from waiting until they’re sick to enroll (which would be unsustainable, since insurance only works if there are enough healthy people paying premiums to offset the costs of the sick people).

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