- Open enrollment for 2018 coverage will be shortened to 6 weeks.
- Consumer advocates are concerned about the shorter OEP.
- Consumers need to plan ahead to avoid OEP rush.
- State-run exchanges have flexibility make OEP longer.
- After open enrollment ends, you’ll need a qualifying event to enroll.
- Enrollment periods help prevent “gaming the system.”
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.
Is the shorter open enrollment period cause for alarm?
With all of the other headlines about health care reform thus far in 2017, the shorter open enrollment period scheduled for this fall hasn’t been getting a whole lot of attention. But it’s certainly something that consumers need to keep in mind. Everyone who has coverage in the individual market (about 16.5 million people) will have just six weeks to select a plan for 2018 (either renewing an existing plan or choosing a new one) and people who want to join the individual market for the first time will also be limited to that same enrollment window.
There is no doubt that enrollment assisters will be particularly busy, given that their window for getting people enrolled will be half as long as it was the last few years. Insurer call centers and exchange call centers will also be dealing with compressed volume during open enrollment. If you feel like you might need help sorting through the available options and getting enrolled in a plan for 2018, you may want to book an appointment with a broker or enrollment counselor well in advance of open enrollment. There will still be walk-in enrollment centers, but you’ll want to plan for the possibility of a significant wait time if you’re going to use one, as those facilities will also be condensing all of their normal volume into half the normal time.
In short, plan ahead. Don’t wait until the last minute to enroll, and don’t forget about the December 15 end of open enrollment. December tends to be a busy month, but if you let open enrollment pass you by, you’ll either be stuck with an auto-renewed (or mapped) plan that may or may not still be the best option for you, or — worse still — you’ll be stuck without insurance for 2018.
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.”
- Connecticut’s exchange will allow people to enroll until December 22, for coverage effective January 1.
- Rhode Island’s exchange will allow people to enroll until December 31, for coverage effective January 1
- 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 (the regular open enrollment period will be supplemented with a special enrollment period from December 16 to January 12, essentially making open enrollment last ten weeks). 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.
- Minnesota‘s state-run exchange, MNsure, announced on August 1 that they would also supplement open enrollment with a special enrollment period that will run from December 16 to January 14. So Minnesota residents will have until January 14 to select a plan for 2018.
- Washington’s exchange will allow enrollments until January 15, 2018. The exchange confirmed by email that they have added a special enrollment period that will run from December 16 to January 15, although they’re encouraging residents to sign up by December 15 so that they can have a January 1 effective date.
- Massachusetts‘ exchange will continue open enrollment through January 23, 2018. In Massachusetts, enrollments can always be submitted by the 23rd of the month for a first of the following month effective date (Rhode Island is the only other state that normally does this; in every other state, the deadline is the 15th). So people in Massachusetts who enroll between December 24 and January 23 will have coverage effective February 1.
- DC‘s exchange is allowing people to enroll until January 31, 2018. This is the originally scheduled open enrollment period for 2018 coverage, which would have been used throughout the country if the federal government hadn’t changed it in the spring of 2017.
- California‘s exchange has decided to retain the originally scheduled open enrollment dates for 2018 coverage. They confirmed by phone in mid-August that their open enrollment period for 2018 coverage will begin November 1, 2017 and continue until January 31, 2018. Normal effective date rules will apply, so applicants will have to enroll by December 15 to get coverage with a January 1, 2018 effective date.
- New York‘s exchange announced in early September that their open enrollment period will run from November 1, 2017 through January 31, 2018 — the full three months that was originally scheduled before CMS changed the dates in April.
In most of those states, the normal effective date rules will apply, so enrollments will need to be completed by December 15 in order to get a January 1 effective date, and enrollments completed after that won’t have coverage effective until February or March. But Rhode Island is letting people enroll as late as December 31 (the end of their open enrollment period) for a January 1 effective date, and in Massachusetts, enrollments completed by December 23 will have coverage effective January 1.
Only state-run exchanges that use their own enrollment platform have flexibility in terms of the dates for open enrollment this fall. There are 12 such states, and as noted above, nine have announced extensions. The remaining three are Idaho, Vermont, and Maryland. As of early September, Idaho’s exchange and Vermont’s exchange had both confirmed that they plan to end open enrollment on December 15, 2017, and are not considering any extensions.
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. 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. Otherwise, you won’t be able to enroll if it’s after December 15.