- Open enrollment for 2021 coverage will run from November 1, 2020 through December 15, 2020 in most states.
- California, Colorado, and Washington, DC, have permanently extended open enrollment.
- State-run exchanges have flexibility to make OEP longer.
- Outside of open enrollment, you’ll need a qualifying event to enroll.
Q. What is the deadline to enroll in health insurance coverage in the individual market?
A. In most states, open enrollment for 2021 health plans is scheduled to run from November 1, 2020 through December 15, 2020. HealthCare.gov, which is the exchange platform that’s used by the majority of the states, tends to follow this schedule fairly closely, while the states that run their own exchange platforms generally offer slightly longer enrollment windows. HealthCare.gov is used in 38 states as of 2020, although this is expected to drop to 35 states by the time the open enrollment window begins in the fall of 2020.
Outside of open enrollment, plan changes and new enrollments are only possible for people who experience a qualifying event.
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: November 1 – January 31. California enacted legislation in 2017 and again in 2019 that permanently establishes different enrollment dates within the state, both on and off-exchange. Open enrollment for 2021 health plans will begin November 1, 2020 and continue through January 31, 2020. California’s enrollment schedule has varied in previous years, but this three-month window, from the beginning of November through the end of January, will be the permanent enrollment window going forward.
Colorado: November 1 – January 15. Colorado’s Division of Insurance has also permanently extended open enrollment. The state finalized regulations in late 2018 that call for an annual special enrollment period, running from December 16 to January 15, that is added to the end of open enrollment each year. 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.
DC: November 1 – January 31. DC’s exchange board voted unanimously to permanently implement an open enrollment window that runs from November 1 to January 31.
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 13 of them as of 2020, and potentially 16 as of 2021 — 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.” Since then, the majority of the state-based exchanges have opted to extend open enrollment for most years.
For 2020 enrollments, Maryland, Vermont, and Nevada opted to keep the December 15 end date (and Idaho came very close to it; their reason for a one-day extension was that their call center isn’t open on Sundays, and the 15th fell on a Sunday. In general, Idaho residents should expect that the enrollment window will not be extended in the future, given how well they’ve adhered to that deadline for the last few years).
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.
Pennsylvania, New Mexico, and New Jersey will have state-run exchange platforms by the fall of 2020; Maine might do so as well by the fall of 2021, and Oregon may join them in the future as well. Fully state-run exchanges are the only ones with the ability to extend open enrollment on their own (in the other states, the decision has to come from CMS, since the extension has to be issued via HealthCare.gov), and most of them have been choosing to do so each year.
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.
- 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 complete guide to qualifying events in the individual market, 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.
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.
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.