- Open enrollment for 2018 coverage was shortened to 6 weeks.
- Consumer advocates were concerned about the shorter OEP.
- Consumers had to plan ahead to avoid OEP rush.
- State-run exchanges had flexibility make OEP longer.
- If your plan ended on 12/31, you have a special enrollment period.
- Outside of open enrollment, you’ll need a qualifying event to enroll.
- Enrollment periods help prevent “gaming the system.”
- Limited enrollment windows have long been the norm for health plans
Q. What is the deadline to enroll in health insurance coverage in the individual market?
A. Open enrollment for 2018 coverage was much shorter than the enrollment window was in previous years, and the shorter enrollment window will continue to be used in future years. It began on November 1, 2017, and in most states, it ended on December 15, 2017. In most states, all plans took effect January 1, 2018; there is no longer an option to switch to a different plan after the first of the year.
Outside of open enrollment, plan changes and new enrollments are only possible for people who experience a qualifying event. But as noted below, there were quite a few extensions and special enrollment periods that allowed many people to enroll well after mid-December.
Originally, open enrollment for 2018 coverage was scheduled to follow the same three-month time frame that the past two open enrollments used (November through January). But in April 2017, HHS finalized a market stabilization rule that includes a variety of changes ostensibly aimed at protecting the stability of the individual health insurance market.
One of the changes made by the new rule was the open enrollment schedule for 2018 coverage. It was reduced to half of what was previously scheduled, although it’s worth noting that the November 1 — December 15 schedule was already slated to take effect in the fall of 2018 (for 2019 coverage). The market stabilization rule just moved it up a year. However, the Trump Administration also drastically reduced funding for outreach, marketing, and enrollment assistance for HealthCare.gov, which is the exchange used by the majority of the states. This was certainly not what the previous administration had in mind when they scheduled the transition to a shorter open enrollment period. If anything, the shorter enrollment period requires more funding, not less.
The open enrollment window applies in the exchanges, and it also applies to plans purchased outside the exchange—with the exception of Nevada. (In Nevada, off-exchange plans—with no subsidies—can be purchased year-round, but the carriers can impose a three-month waiting period before coverage takes effect.)
State-run exchanges had some flexibility on open enrollment for 2018
The market stabilization rule noted that the November 1 — December 15 open enrollment period would apply in every state in the fall of 2017. However, they also noted that some state-based exchanges — there are 12 of them — might experience logistical difficulties in getting their systems ready for the new schedule on a fairly tight timeframe (the rule was finalized in April, and open enrollment began less than seven months later).
As such, the market stabilization rule clarified that state-based exchanges could use their own flexibility to “supplement the open enrollment period with a special enrollment period, as a transitional measure, to account for those operational difficulties.” Ten of the 12 state-based exchanges that use their own enrollment platform ultimately opted to extend open enrollment:
- Connecticut’s exchange allowed people to enroll until December 22, for coverage effective January 1.
- Maryland‘s exchange allowed enrollments until December 22, for coverage effective January 1. Unlike the other exchanges that planned their extensions well in advance of open enrollment, this was a last-minute announcement.
- Rhode Island’s exchange allowed people to enroll until December 31, for coverage effective January 1
- Colorado allowed people to enroll until January 12. Enrollments completed between December 16 and January 12 had coverage effective February 1.
- Minnesota‘s state-run exchange, MNsure, announced on August 1 that Minnesota residents would have until January 14 to select a plan for 2018. MNsure also extended the deadline for a January 1 effective date: residents who enrolled by December 20 had coverage effective January 1, 2018.
- Washington’s exchange allowed enrollments until January 15, 2018, although they encouraged residents to sign up by December 15 so that they could have a January 1 effective date.
- Massachusetts‘ exchange continued 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 enrolled by December 23 had coverage effective January 1. Those who enrolled between December 24 and January 23 had coverage effective February 1.
- DC‘s exchange initially extended open enrollment until until January 31, 2018, but they made another last-minute extension through February 5, 2018, making theirs the longest open enrollment period in the country.
- California‘s exchange also retained the originally scheduled open enrollment dates for 2018 coverage, with enrollment continuing until January 31, 2018. Covered California allowed residents to enroll until December 22 for coverage effective January 1, and they announced on January 31 that people who began the enrollment process by midnight on January 31 would have until February 2 to finish the enrollment process.
- New York‘s exchange announced in early September that their open enrollment period would run from November 1, 2017 through January 31, 2018 — the full three months that was originally scheduled before CMS changed the dates in April.
In most of those states, the normal effective date rules applied, so enrollments had to be completed by December 15 in order to get a January 1 effective date, and enrollments completed after that date resulted in coverage effective in February or March. But six of the state-run exchanges implemented enrollment deadlines after December 15 for people who wanted January 2018 coverage.
Only state-run exchanges that use their own enrollment platform had flexibility in terms of the dates for open enrollment for 2018 coverage. There are 12 such states, and as noted above, ten extended their open enrollment periods. But the exchanges in Idaho and Vermont ended open enrollment on December 15, 2017.
Outside of the open enrollment window, enrollment is only available with a qualifying event
After open enrollment ended on December 15, 2017 (or later, if you’re in one of the states with an extended deadline), people can only purchase coverage for 2018 if they have a special enrollment period triggered by a qualifying event such as:
- Becoming a U.S. citizen,
- Birth or adoption,
- Involuntary loss of other health coverage (this will allow many people to select a new plan as late as March 1, 2018, due to insurers exiting the market in various areas around the country; see details below).
- 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.
There was also an exceptional circumstances special enrollment period through December 31, 2017 for people in areas that were hit hardest by the 2017 hurricane season and the windstorms that affected much of Maine. The special enrollment period applied to residents of five full states, three partial states, and anyone who had lived in the US Virgin Islands or Puerto Rico during the hurricanes.
Regardless of whether you purchase insurance through the exchange or off-exchange, the annual open enrollment window applies, and special enrollment periods are necessary in order to enroll at any other time of the year. 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.
In 2016, HHS tightened up the rules regarding eligibility for special enrollment periods, and they further tightened the rules in 2017, as part of the market stabilization rule. As a result, the rules are being followed much more closely than they were in previous years, and in most states, anyone enrolling during a special enrollment period is required to provide proof of the qualifying event that they experienced
Native Americans and Alaska Natives can enroll year-round. Applicants who are eligible for Medicaid can also enroll year-round.
Special rule for loss of coverage
If you had a health plan that was terminated on December 31 for reasons other than non-payment of premium or fraud, you are eligible for a special enrollment period, as loss of coverage is a qualifying event. In order to take advantage of this provision, you’ll need to check the box on the application that says you’re enrolling because you lost coverage.
There are at least 19 insurers across the country, some of which offer plans in several states, that exited the exchanges or the entire individual market at the end of 2017.
- People who had on-exchange coverage with these plans were mapped to plans with different insurers if they didn’t return to the exchange to pick a new plan by December 15. But they’re still eligible for a special enrollment period (which continues through March 1, 2018) during which they can return to the exchange and pick a different plan.
- People who had off-exchange coverage with these plans generally became uninsured as of January 1 if they didn’t pick a new plan for themselves, as there’s no entity available to automatically select a new plan for them. But the same special enrollment period applies to off-exchange enrollees — they have until March 1, 2018, to sign up for a new plan (albeit with a gap in coverage if they didn’t sign up by December 31, as the earliest available effective date after that point was February 1).
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).
Shorter open enrollment is controversial
The reason the open enrollment period was shortened was to ensure that as many people as possible are enrolled in coverage for the full year. In the past, open enrollment continued throughout January (or even later, in the case of the initial open enrollment periods), which meant that people could sign up near the end of open enrollment and get a plan that took effect in March.
The idea behind the new schedule is that everyone has coverage that starts in January, making people more likely to pay for a full year of coverage. The new schedule also removes the ability for people to “game the system” by signing up in November for an expensive plan, utilizing it for a planned expense (a surgery, for example) in January, and then switching to a lower-cost plan with an effective date in February or March. It also eliminates the adverse selection that would otherwise occur when people don’t plan to enroll but then find out in late December or January that they’re in need of health care.
But on the other side of the coin, there has been considerable concern among consumer advocates, brokers, and other enrollment assisters who worry that six weeks just isn’t enough time to help everyone get enrolled. The new open enrollment period mostly overlaps with open enrollment for Medicare Advantage and Medicare Part D, and many of the brokers who help people enroll in individual market plans are also helping people enroll in Medicare during the same time, stretching their resources.
There have also been concerns that the shorter open enrollment period might mean that fewer young, healthy people will enroll in individual market coverage. Sick people tend to enroll as soon as open enrollment begins, so they’ll enroll regardless of the schedule. But young, healthy people — the people who are needed in order to keep the risk pools stable — are more likely to procrastinate and enroll at the last minute. The shorter open enrollment period might mean that they just don’t enroll at all, with total enrollment ending up lower than it would have been with the longer enrollment period.
But despite the shorter enrollment period and the funding cuts that the Trump Administration made for marketing and enrollment assistance, enrollment in plans for 2018 was only slightly lower than it had been the year before. Almost 11.8 million people enrolled in exchange plans for 2018, versus about 12.2 million for 2017.