Q. What is the deadline to enroll in health insurance coverage for 2018?
A. Open enrollment for 2018 coverage will be much shorter than it’s been in previous years. It will begin on November 1, 2017, and end on December 15, 2017. All plans will take effect January 1, 2018; there will no longer be an option to switch to a different plan after the first of the year. After December 15, enrollment and plan changes will only be possible for people who experience a qualifying event.
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 aimed at protecting the stability of the individual health insurance market.
One of the changes made by the new rule is the open enrollment schedule for 2018 coverage. It’s been 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.
The open enrollment window applied in the exchanges, and it also applied 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.)
Shorter open enrollment is controversial
The reason the open enrollment period is being shortened is 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 will have coverage that starts in January, and thus be 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 is considerable concern among consumer advocates, brokers, and other enrollment assisters who are worried that there just won’t be 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 are also 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, and that total enrollment ends up being lower than it would have been with the longer enrollment period.
State-run exchanges have some flexibility on open enrollment for 2018
The market stabilization rule notes that the November 1 — December 15 open enrollment period will apply in every state in the fall of 2017. However, they also note 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 begins in November).
As such, the market stabilization rule clarifies that state-based exchanges can 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.”
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. 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.
After December 15, enrollment will only be available with a qualifying event
After open enrollment ends on December 15, 2017, you’ll only be able to purchase coverage for 2018 if you experience a qualifying event that triggers a special enrollment period. 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.
In short, 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.
Special rule for loss of coverage
If you have a health plan that is going to be 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.
If your plan ends altogether (which is not the same thing as simply being mapped to a modified plan) and renewal is not available, you’ll have 60 days after your coverage ends to enroll in a new plan. (This is true any time a plan ends – even if it happens in the middle of the year, and the special enrollment period also extends for 60 days prior to the loss of coverage; the best option is to enroll prior to the old plan’s termination date, so that you don’t have a gap in coverage.) If your coverage terminates on December 31, 2017, your special enrollment period will continue until March 1, 2018.
So if your insurer is exiting the market or otherwise terminating your plan and not replacing it at the end of 2017, you’ll have a 60-day special enrollment period at the start of 2018. This would apply to anyone with an off-exchange plan that’s ending, although the exchanges now have processes for mapping people to plans from other insurers in most cases, to prevent a gap in coverage.
The special enrollment period triggered by loss of coverage allows for an effective date the first of the following month, even if you enroll on the final day of the month during your special enrollment period. So a person who is losing coverage December 31 can enroll on December 31 and have coverage effective January 1 (despite the fact that under normal open enrollment period rules, the deadline to enroll for January 1 coverage would have been December 15).
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.