Obamacare open enrollment deadlines
- In most states, open enrollment for 2020 coverage runs from November 1 – December 15, 2019.
- CALIFORNIA, COLORADO, and DC have permanently extended open enrollment.
- Ten state-run exchanges extended open enrollment for 2019. Some may do so again for 2020.
- The open enrollment schedule has changed several times
- State-run exchanges have flexibility to make OEP longer.
- If your plan ends on 12/31, you’ll 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
- Consumer advocates worry that the shorter enrollment period makes it harder for people to enroll.
Q. What is the deadline to enroll in health insurance coverage in the individual market?
A. In most states, open enrollment will begin November 1, and end December 15, with all plans effective January 1, 2020. In most states, there is no longer an option to switch to a different plan after the first of the year (state-run exchanges have some flexibility on enrollment schedules, and some are offering longer enrollment periods, described below).
Outside of open enrollment, plan changes and new enrollments are only possible for people who experience a qualifying event. In some cases in recent years, qualifying events have included hurricanes, floods, and other natural disasters that have had widespread impact and have effectively extended open enrollment for people in the affected regions. These extensions are issued on a case-by-case basis, however, based on FEMA disaster designations.
Native Americans and Alaska Natives can enroll year-round in plans offered in the exchange. Applicants who are eligible for Medicaid or CHIP can also enroll year-round.
California, Colorado, and DC: Open enrollment has been permanently extended
California has enacted legislation that permanently establishes different enrollment dates within the state, both on and off-exchange. From now on, open enrollment in California will begin on October 15, and end on January 15. People who enroll between October 15 and December 15 will have coverage effective January 1, while those who enroll between December 16 and January 15 will have coverage effective February 1.
Colorado’s Division of Insurance has also permanently extended open enrollment. State regulators published draft regulations in August 2018 calling for an annual special enrollment period, running from December 16 to January 15, that will be added to the end of open enrollment each year. The regulations were finalized in November 2018, adding the “annual market stabilization special enrollment period,” so open enrollment in Colorado will effectively last 2.5 months for all future enrollment periods (November 1 to January 15). Plans selected between December 16 and January 15 must take effect no later than February 1.
In DC, the exchange board voted unanimously to permanently implement an open enrollment window that runs from November 1 to January 31.
10 state-run exchanges extended open enrollment for 2019
Most states use HealthCare.gov for exchange enrollment, so they have to follow the November 1 – December 15 enrollment schedule. In recent years, extensions for HealthCare.gov enrollments have generally only been issued for people who begin their enrollment — or at least contact the exchange to start the process — by the end of the day on December 15.
But states that run their own enrollment platforms have more flexibility in terms of extending open enrollment. There are a total of 12 state-run exchanges that operate their own enrollment platforms (that will grow to 13 when Nevada switches to their own enrollment platform in the fall of 2019; Pennsylvania, New Mexico, New Jersey, and possibly Oregon will join them in the fall of 2020). They are the only ones with the ability to extend open enrollment, and most of them chose to do so in past years. Ten of them extended open enrollment for 2019 coverage, including Vermont and Washington, both of which issued their extensions after open enrollment had closed.
We won’t know until closer to open enrollment (or in some cases, the end of open enrollment) whether these exchanges will once again offer extensions for 2020 enrollment. But for historical perspective, here’s a look at the extensions that state-run exchanges issued for 2019 enrollment:
- California: January 15 (this extension is permanent)
- Colorado: January 15 (this extension is permanent)
- DC: February 6 (an extension to January 31 is permanent)
- New York: January 31
- Massachusetts: January 23
- Connecticut: January 15
- Minnesota: January 13
- Vermont: December 21
- Washington: December 20
- Rhode Island: December 31
The remaining two states that use their own enrollment platforms — Idaho and Maryland — followed the November 1 – December 15 schedule and did not offer any extensions. Idaho had already transitioned to the shorter enrollment period for 2018 coverage, with no extensions. And although Maryland did issue an extension for 2018 enrollment, they did not do so for 2019 enrollment
Open enrollment schedules: A history
For 2014 coverage, when the bulk of the ACA’s provisions were first being implemented, open enrollment lasted six months (October 1, 2013 to March 31, 2014), in an effort to give everyone enough time to get used to the new system and enroll.
For 2015, 2016, and 2017 coverage, open enrollment lasted for three months. 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 included 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 have some flexibility on open enrollment schedule
The 2017 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 will be 13 of them as of the fall of 2019 — might experience logistical difficulties in getting their systems ready for the new schedule on a fairly tight timeframe.
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 for 2018 (only Idaho and Vermont kept the December 15, 2017 end date).
As we can see from the decisions in DC, California, and Colorado (to permanently extend open enrollment) states with their own enrollment platforms still have flexibility going forward. HHS has defined open enrollment as the window from November 1 to December 15, and that applies in every state. But state-run exchanges have the option to offer special enrollment periods before or after that window, in order to effectively extend open enrollment (California’s legislation adds a special enrollment period before and after the federally-set open enrollment period; Colorado is adding a special enrollment period after the end of the regular open enrollment period).
Outside of the open enrollment window, enrollment is only available with a qualifying event
After open enrollment ends, people can only purchase coverage if they have a special enrollment period triggered by a qualifying event such as:
- Marriage (since 2017, this generally only applies if at least one spouse already had coverage before the wedding, although there are some exceptions),
- Becoming a U.S. citizen,
- Birth or adoption,
- Involuntary loss of other health coverage (this allows people to select a new plan in the first two months of the year if their insurer leaves the market at the end of the previous year; see details below).
- A permanent move to an area where new health plans are available (since July 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.
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
Special rule for loss of coverage
If your health plan is 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.
People who have on-exchange coverage with an insurer that leaves the market are mapped to plans with different insurers if they don’t return to the exchange to pick a new plan by December 15. But in most states, they’re still eligible for a special enrollment period (which continues for 60 days after the old plan ends) during which they can return to the exchange and pick a different plan.
People who have off-exchange coverage with an insurer that leaves the market are generally uninsured as of January 1 if they don’t pick a new plan for themselves by December 31, 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 60 days after the old plan ends to sign up for a new plan (albeit with a gap in coverage if they don’t sign up by December 31, as the earliest available effective date after that point is February 1).
In 2017 and 2018, numerous insurers exited the exchanges, leaving many people having to pick new plans. But for 2019, we saw the opposite trend, with insurers joining the exchanges in many states (insurers joined the exchanges in Arizona, Florida, Illinois, Iowa, Maine, Massachusetts, Michigan, Missouri, New Mexico, North Carolina, Ohio, Oklahoma, Pennsylvania, South Carolina, Tennessee, Utah, Virginia, and Wisconsin). The rate and plan filing window for 2020 coverage got underway in May/June 2019, so data is still very preliminary. But so far, it does not appear that there will be any widespread insurer exits from the exchanges, and there are some once again insurers joining the exchanges in some areas for 2020.
But even when insurers remain in the exchange, they can change their coverage area from one year to the next. If an insurer exits a particular area of a state, people who had plans with that insurer in that area are eligible for a special enrollment period due to loss of coverage. The same is true if, for example, an insurer terminates all of the PPO plans they have and replaces them with HMOs. The people who had the plans that are terminated can opt to just accept the new HMO plan, but they also qualify for a special enrollment period during which they can pick a different plan.
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 of 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 anytime 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 Obama Administration had planned to shorten open enrollment (the Trump Administration moved this up a year, implementing it in the fall of 2017 instead of 2018) 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 (note that this can be a counterproductive approach, as the out-of-pocket maximum would reset to zero when the new plan starts; if the person ends up needing medical care during the remainder of the year, they’d be starting from scratch on their deductible and out-of-pocket, without getting credit for the cost-sharing amount they paid under the more robust plan). 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.
For 2019, enrollment ended only a little lower, at about 11.4 million, despite the fact that the individual mandate penalty has been eliminated. The Congressional Budget Office projected that 3 million fewer people will obtain coverage in the individual market in 2019 as a result of the elimination of the mandate penalty. And while off-exchange enrollment has likely dropped precipitously, on-exchange enrollment only dropped by a few hundred thousand people.
In addition, the Trump Administration has finalized rules that expand access to short-term health insurance plans and has also finalized a rule that expands access to association health plans. Both types of coverage will be more likely to appeal to healthy people, which could have resulted in fewer people signing up for ACA-compliant health plans during open enrollment for 2019 coverage. But again, many of those individuals may have had coverage in the off-exchange market prior to 2019, so their enrollments and plan changes are not as closely tracked.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.