Q: What are the Affordable Care Act enrollment periods and when can I enroll outside of the open enrollment period?
A: Open enrollment for 2017 began on November 1, 2016, and ended on January 31, 2017. These dates were for both on and off-exchange plans. In most states, the deadline to enroll in a plan with a January 1, 2017 effective date was December 19, 2016 (Massachusetts, Rhode Island, and Washington state all allowed enrollments to be completed as late as December 23 and still have coverage effective January 1; the December 19 deadline in most other states was an extension, as the normal deadline would have been December 15).
Minnesota’s exchange added a special enrollment period that runs from February 1 to February 8, 2017, allowing residents one additional week to enroll in coverage and take advantage of the new state-based premium rebate that Minnesota lawmakers approved in late January. In most of the rest of the states, enrollments begun by the end of the day on January 31 are being completed with the help of exchange staff to ensure that people get the coverage they tried to purchase during open enrollment.
In the Benefit and Payment Parameters for 2017, HHS confirmed that they will maintain this same November 1 to January 31 open enrollment period for 2018 coverage as well (ie, open enrollment for 2018 coverage will begin on November 1, 2017 and will end on January 31, 2018).
But after that, for coverage effective in 2019 and beyond, open enrollment will be shorter, and will end before the start of the coverage year. It will run from November 1 to December 15, with coverage effective January 1.
Open enrollment schedule under the Trump Administration
The future of the ACA — including scheduled enrollment periods — is very much up in the air under the Trump Administration (you can see more in our Repeal & Replace section). Republican proposals for replacing the ACA don’t necessarily rely on open enrollment periods. Some call for guaranteed-issue coverage only for people who maintain continuous coverage, and medical underwriting (or high-risk pool coverage) for those who don’t.
But Congressional leaders have said the implementation of their ACA repeal is likely to be delayed by at least two years, meaning that open enrollment will likely continue as scheduled for 2018, and possibly beyond.
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:
- Becoming a U.S. citizen,
- Birth or adoption,
- Involuntary loss of other health coverage
- Permanent move to an area where new health plans are available (since July 11, 2016, this only applies in most cases if you already had coverage prior to your move).
- Here’s a full list of qualifying events and their associated special enrollment periods.
Starting in 2016, Healthcare.gov began requiring proof of eligibility for the most common qualifying events, and they were planning to further step up their eligibility verification process in 2017 (note that all HHS regulations are subject to change under the Trump Administration, and regulations pertaining to the ACA are very likely to change; so the guidelines relating to eligibility verification for HealthCare.gov special enrollment periods might not continue as planned in 2017).
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.
Open enrollment for 2017 ended on January 31, 2017. After that, if you don’t experience a qualifying event in 2017, your next opportunity to enroll will be November 1, 2017, when open enrollment begins again. Coverage selected at that point will be effective as of January 1, 2018.
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).