- Open enrollment for 2019 coverage: November 1 to December 15 in most states
- CALIFORNIA: open enrollment set at October 15 to January 15
- Open enrollment schedule has changed several times
- State-run exchanges have flexibility make OEP longer.
- If your plan ends 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
- Consumer advocates were concerned about the switch to shorten OEP for 2018.
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, in nearly every state.
Open enrollment begins November 1, and ends December 15, with all plans effective January 1 of the coming year. 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 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. So for 2019 coverage, California residents will be able to enroll starting on October 15, 2018, and will have until January 15, 2019 to enroll.
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 coverage, open enrollment lasted for three months, from November 15, 2014 to February 15, 2015.
For 2016 and 2017 coverage, it was again three months, but with slightly different dates: November 1 to January 31.
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 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 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.
The exchanges in Connecticut and Maryland added one extra week (through December 22), while the exchanges in DC, California, and New York opted to keep the orginally scheduled November 1 – January 31 open enrollment schedule. Most of the other state-run exchanges implemented extensions somewhere in the middle, although the exchanges in Idaho and Vermont ended open enrollment on December 15, 2017.
As we can see from California’s decision to enact legislation on this issue, 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).
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 left 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 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.
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 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).
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 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 open enrollment period was shortened for 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. 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.
That will likely drop considerably for 2019, however, when the individual mandate penalty is eliminated. People who are uninsured in 2018 are still subject to a penalty, which will be collected on 2018 tax returns. But that will not be the case for people who are uninsured in 2019, and the Congressional Budget Office projects that 3 million fewer people will obtain coverage in the individual market in 2019 as a result.
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.