Q. What’s the deadline to enroll in health insurance coverage for 2016?
A. In every state, the deadline to enroll in individual health insurance through the exchange was January 31. This is also true for 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).
Three extensions announced
During the first two open enrollment periods, Healthcare.gov and most of the state-run exchanges extended the final deadline for enrollment. This time around, Healthcare.gov did not extend enrollment, other than to help people complete enrollments that were begun by midnight on January 31.
Just three state-run exchanges announced open enrollment extensions, and two of them only apply to people who began their enrollments by January 31:
- Maryland: The exchange tweeted that anyone who begins the process by January 31 but is unable to finish on time due to the recent snowstorm, will have until February 5 to complete the enrollment. Enrollments had to be started by January 31, and enrollees must attest that the January blizzard interrupted their ability to finish enrolling by the end of January.
- California: The exchange issued a press release stating that anyone who begins the process by January 31 but is unable to finish on time will have until February 6 to complete the enrollment.
- Washington DC: Due to the blizzard on the east coast in late January, the DC exchange gave all residents an additional two days to enroll. The new deadline was February 2 at 11:59pm. Enrollments completed by February 2 in DC will have coverage effective March 1. DC was the only exchange to issue a blanket extension for all residents, including those who didn’t begin the enrollment process by January 31.
In Washington state, the system that determines Medicaid and subsidy eligibility was down for most of the day on January 30. For people whose enrollment was delayed as a result of the outage, the exchange will decide on a case-by-case basis whether to grant additional time to enroll. If you’re in this situation, call Washington Healthplanfinder at 1-855-923-4633 by February 7 to see if you can get an extension.
2016 penalty for being uninsured
The penalty for being uninsured doesn’t apply to people who have one short gap in coverage of less than three months (note that the penalty does apply if you’re uninsured for three months or longer), so everyone who enrolled by the end of open enrollment (or by the extensions mentioned above) will have coverage in effect no later than March 1. As long as they maintain that coverage for the remainder of the year, they won’t face a penalty on their 2016 tax return.
For people who remain uninsured, the penalty for not having coverage is significantly higher in 2016 than it was in 2014 and 2015 (there are several circumstances under which you can get an exemption from the penalty).
Enrollment now only available with a qualifying event
Now that open enrollment has ended, you can only purchase coverage for 2016 if you experience a qualifying event. Also, in a change from the previous two years, HHS will be conducting audits in 2016 to ensure that special enrollment period regulations are being properly enforced, and that enrollees are providing proof of their qualifying events when they sign up.
No tax season special enrollment period
CMS has confirmed that there will be no “tax season” special enrollment period this time around.
2015 was the first time that people had to pay the ACA’s penalty for being uninsured (assessed for being uninsured in 2014, and paid on their 2014 tax returns that were filed in 2015). Understandably, a lot of people were caught off guard by the penalty, and by the time they filed their returns, open enrollment had already ended. Without a special enrollment period, all of those people would have been stuck having to pay the penalty for 2015 as well, since their opportunity to enroll in a plan for the year had already passed. To mitigate the problem, all but three states agreed to allow a special enrollment period in the spring of 2015 so that people who had to pay the penalty for 2014 would have an opportunity to enroll in coverage for most of 2015.
There will be no similar extension this year, since Americans are now used to the idea that their tax returns include health insurance data, and that there’s a penalty for being uninsured.
Special rule for loss of coverage
If you had a health plan that was terminated on December 31, or if your insurer exited the market at the end of 2015 (for example, this was the case for ten CO-OPs, everyone who had WINhealth in Wyoming, and Moda Health or Columbia United Providers in Washington), you’re eligible for a special enrollment period, triggered by qualifying event – loss of coverage.
So if your plan ended altogether (which is not the same thing as simply being mapped to a modified plan) and renewal was not available, you have 60 days after your coverage ended to enroll in a new plan. For people whose plans terminated on December 31, the special enrollment period continues until February 29. For anyone enrolling in a new plan on January 1 or later, there will be a gap in coverage, as there’s no provision to allow for a retroactive effective date following loss of coverage.
Also, exchanges have flexibility in terms of the effective dates they assign during a special enrollment period following loss of coverage. In the 60 days prior to loss of coverage, they have to allow for the new coverage to be effective the first of the month following the loss of coverage, regardless of the enrollment date. But in the 60 days after the date coverage ends, the exchange can decide whether to use the normal effective date guidelines (in most states, this means enrollment must be completed by the 15th of the month in order to have coverage effective the first of the following month), or to allow a first-of-the-following-month effective date, regardless of the date the enrollment is completed. If you’ve got a special enrollment period triggered by loss of coverage, check with the exchange in your state to see how they’ll assign your effective date.