Q. What is the deadline to enroll in health insurance coverage for 2017?
A. Open enrollment for 2017 coverage will begin on November 1, 2016, and will continue until January 31, 2017 (that’s the same schedule that was used for 2016 coverage, and it will also be used for 2018 coverage. But starting with 2019 coverage, the open enrollment window will be different).
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).
December 15 = last day to get January effective date in most states
In Massachusetts, Rhode Island, and Washington state, you can enroll as late as Decembr 23 and still have coverage effective January 1. But in every other state (regardless of whether you’re enrolling on or off-exchange), you’ll need to enroll by December 15 in order to have coverage effective January 1.
January 31 = the last day to enroll
During the first two open enrollment periods, Healthcare.gov and most of the state-run exchanges extended the final deadline for enrollment. But for 2016 coverage, Healthcare.gov and the majority of the state-run exchanges did not extend enrollment, other than to help people complete enrollments that were begun by midnight on January 31.
For 2017 coverage, expect that January 31 will be a hard deadline. After that, enrollments will only be available for 2017 if you experience a qualifying event.
2017 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 time (note that the penalty does apply if you’re uninsured for three months or longer). If you enroll in coverage by the end of January 2017, you’ll have coverage in place no later than March 1, 2017. As long as you maintain it for the remainder of the year, you won’t face a penalty for 2017.
For people who remain uninsured, the penalty for not having coverage grew significantly in 2016. It will remain at the 2016 rate going forward, but the flat-rate amount will be adjusted annually for inflation (there are several circumstances under which you can get an exemption from the penalty).
After January 31, enrollment only available with a qualifying event
Once open enrollment ends, you’ll only be able to purchase coverage for 2017 if you experience a qualifying event. In 2016, HHS tightened up the rules regarding eligibility for special enrollment periods. They also began conducting audits to ensure that special enrollment period regulations were being properly enforced, and that enrollees were providing proof of their qualifying events when they sign up.
In short, the rules are being followed much more closely than they were in 2014. If you want health insurance for 2017, make sure you enroll by January 31 at the latest.
Special rule for loss of coverage
If you have a health plan that’s being terminated on December 31, or if your insurer is exiting the market at the end of 2016, you will be eligible for a special enrollment period, as loss of coverage is a qualifying event.
This will be the case for people in numerous states—for example, CO-OP enrollees in Connecticut, UnitedHealthcare enrollees in most of the states where United currently offers individual market coverage, Oregon residents whose plan will no longer be available due to shrinking coverage areas for existing carriers, etc.
If your plan is ending 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 anytime 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). If your coverage is terminating on December 31, your special enrollment period will continue until February 29.
But in order to have seamless coverage—with your new plan effective January 1—you’ll need to enroll no later than December 31 (although December 15 is the last day you can enroll for a January 1 effective date in most states under normal open enrollment rules, 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 in which your old plan ends; in order to take advantage of this provision between December 16 and December 31, you’ll need to make sure you’re using your special enrollment period, even though it will coincide with general open enrollment). If you enroll in January or February, your new plan will take effect sometime between February and April, which means you’ll have a gap in coverage in the early part of 2017.