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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 acknowledged that state-run exchanges might run into technical difficulties since the open enrollment schedule was changed late in the game, in April 2017.

By early September, several state-run exchanges had already announced open enrollment extensions, well in advance of open enrollment:

  • Colorado announced on June 22 that the open enrollment period for 2018 coverage in Colorado would run from November 1, 2017, to January 12, 2018, both on and off-exchange (the regular open enrollment period will be supplemented with a special enrollment period from December 16 to January 12, essentially making open enrollment last ten weeks). This ten-week open enrollment is intended to serve as a more gradual transition to the shorter open enrollment that was already scheduled for the fall of 2018.
  • Minnesota’s state-run exchange, MNsure, announced on August 1 that they would also supplement open enrollment with a special enrollment period that will run from December 16 to January 14. So Minnesota residents will have until January 1 to select a plan for 2018.
  • DC’s exchange is allowing people to enroll until January 31, 2018. This is the originally scheduled open enrollment period for 2018 coverage, which would have been used throughout the country if the federal government hadn’t changed it in the spring of 2017.
  • Rhode Island’s exchange will allow people to enroll until December 31, for coverage effective January 1.
  • Washington’s exchange will allow enrollments until January 15, 2018. The exchange confirmed by email that they have added a special enrollment period that will run from December 16 to January 15, although they’re encouraging residents to sign up by December 15 so that they can have a January 1 effective date.
  • California’s exchange has decided to retain the originally scheduled open enrollment dates for 2018 coverage. They confirmed by phone in mid-August that their open enrollment period for 2018 coverage will begin November 1, 2017 and continue until January 31, 2018. Normal effective date rules will apply, so applicants will have to enroll by December 15 to get coverage with a January 1, 2018 effective date.
  • Massachusetts‘ exchange will continue open enrollment through January 23, 2018. In Massachusetts, enrollments can always be submitted by the 23rd of the month for a first of the following month effective date (Rhode Island is the only other state that normally does this; in every other state, the deadline is the 15th). So people in Massachusetts who enroll between December 24 and January 23 will have coverage effective February 1.
  • New York’s exchange announced in early September that their open enrollment period will run from November 1, 2017 through January 31, 2018 — the full three months that was originally scheduled before CMS changed the dates in April.
  • Connecticut’s exchange will allow people to enroll until December 22, for coverage effective January 1.

But some state-run exchanges are not changing the open enrollment schedule. As of early September, Idaho’s exchange and Vermont’s exchange had both indicated that they plan to end open enrollment on December 15, 2017.

In states where open enrollment ends December 15, all plans will be effective January 1. In states with extensions, enrollments after December 15 will generally result in February or March effective dates, but Rhode Island will make all plans effective January 1, even for people who sign up on December 31. Connecticut will also make all plans effective January 1, including for people who enroll between December 16 and December 22. And in Massachusetts, the normal deadline is the 23rd of the month for a first of the following month effective date, so people can enroll until December 23 and get coverage effective January 1.

Hurricane victims in designated areas can enroll until December 31

In late September, HHS announced a special enrollment period (SEP) for the people most heavily affected by Hurricane Irma and Hurricane Harvey. The SEP will continue until December 31, 2017, effectively adding a little more than two weeks to open enrollment. To be eligible for the SEP, you have to reside in (or have resided in at the time of the hurricane) one of the counties that FEMA declared eligible for “individual assistance” or “public assistance.”

That includes:

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).