- Open enrollment for 2021 coverage ended on December 15, 2020 in most states, but a COVID-related special enrollment period has been opened, running through August 15 in most states.
- All of the state-run exchanges are offering a COVID-related special enrollment period in early 2021.
- California, Colorado, and Washington, DC, have permanently extended open enrollment, and most of the other state-run exchanges extended open enrollment for 2021 coverage.
- State-run exchanges have flexibility to make OEP longer.
- Outside of open enrollment, you normally need a qualifying event to enroll.
Q. What is the deadline to enroll in 2021 health insurance coverage in the individual market?
A. In most states, open enrollment for 2021 health plans ended on 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.
But the Biden administration has opened a COVID-related special enrollment period on HealthCare.gov. It runs from February 15, 2021 through August 15, 2021, and is available for anyone who is eligible to use the marketplace, including people who are currently uninsured as well as those who already have coverage through HealthCare.gov and would prefer to pick a different plan. A qualifying event is not necessary in order to use this window.
HealthCare.gov is used in 36 states for enrollment in 2021 health plans, and the special enrollment period is available in all of them. In addition, all of the state-run exchanges are offering similar COVID-related special enrollment periods in 2021, although some are only available to people who are otherwise uninsured (or covered by something like a short-term health plan, sharing ministry plan, etc.):
- California: February 1 to May 15
- Colorado: February 8 to May 15
- Connecticut: February 15 to April 15
- DC: Through the end of the pandemic emergency period
- Idaho: March 1 to March 31
- Maryland: Through May 15 (retroactive coverage is available, depending on when a person enrolls)
- Massachusetts: Through July 23
- Minnesota: February 16 to May 17
- Nevada: February 15 to May 15
- New Jersey: Through May 15
- New York: Through May 15
- Pennsylvania: February 15 to May 15
- Rhode Island: Through May 15
- Vermont: February 16 to May 14
- Washington: February 15 to May 15
Outside of open enrollment, plan changes and new enrollments are normally only possible for people who experience a qualifying event, but the COVID-related special enrollment periods in most of the country are providing significant flexibility on this for 2021 coverage.
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. This is true every year, not just in 2021.
States where open enrollment ended on December 15, 2020 but COVID special enrollment period runs from February 15 to August 15, 2021
In the following states, open enrollment ended on December 15, but a COVID-related special enrollment period is available from February 15 to August 15, allowing people another opportunity to enroll or change their coverage:
- New Hampshire
- New Mexico
- North Carolina
- North Dakota
- South Carolina
- South Dakota
- Vermont (COVID-related enrollment period ends May 14, 2021)
- West Virginia
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 began November 1, 2020 and will 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.
All three of those state-run exchanges have also announced COVID-related special enrollment periods for uninsured residents. In DC, it’s been ongoing throughout the pandemic. In California and Colorado, it starts in early February.
In addition to the three permanent extensions described above, open enrollment for 2021 health plans was also extended in ten of the other 12 fully state-run exchanges. Vermont and Maryland were the only states with fully state-run exchanges where open enrollment for 2021 coverage was not extended. But Maryland is among the states offering a COVID-related special enrollment period for 2021 coverage.
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, and they continue to have flexibility with the enrollment schedule 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.
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).
For 2021 enrollments, only Vermont and Maryland opted to keep the December 15 end date (and as noted above, Maryland has reopened enrollment for any uninsured resident, through March 15, 2021, in response to the COVID pandemic).
New Mexico and Kentucky plan to have their own enrollment platforms by the fall of 2021, and Maine might do so as well by the fall of 2021. 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 normally 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. The COVID-related special enrollment periods in 2021 are an exception to the normal rules, in that qualifying events are not necessary in order to use these enrollment windows.
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 insurance marketplace updates are regularly cited by media who cover health reform and by other health insurance experts.