- Open enrollment for 2022 coverage will start November 1, 2021. In most states, it will end January 15, although people will need to enroll by December 15 to have coverage effective January 1.
- Most of the state-run exchanges have picked January 15 or January 31 as the end date for open enrollment this year.
- There are several state-run exchanges where enrollment is ongoing for 2021 plans, and people in most states who have received unemployment compensation in 2021 can still enroll.
- California, Colorado, and Washington, DC, have permanently extended open enrollment, and most of the other state-run exchanges tend to extend open enrollment each year (and there’s been a trend towards states switching to fully state-run exchanges).
- Fully state-run exchanges (15 in 2021; growing to 18 for 2022) have always had the 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 2022 ACA-compliant health insurance coverage in the individual market? Is 2021 coverage still available?
A. Open enrollment for 2022 health coverage starts nationwide on November 1, 2021. In most states, it will end January 15, 2022, although enrollments will need to be completed by December 15 to have coverage effective January 1 (enrollments completed between December 16 and January 15 will have coverage effective February 1 instead).
The January 15 end date includes a one-month extension that has been added by the Biden administration. For the past several years, open enrollment has ended on December 15, but the January 15 deadline will be used from now on.
What are the Obamacare open enrollment deadlines for state-run exchanges?
The new rules clarify that states that run their own exchanges are still free to set their own enrollment deadline, as long as it’s not earlier than December 15. For 2022 coverage, New Mexico, Maine, and Kentucky will have a fully state-run exchange, joining the 15 that already operate as of 2021. So there will be 18 fully state-run exchanges that have the option to extend open enrollment.
For now, the following deadlines have been announced by the state-run exchanges (note that changes could still be made during the open enrollment window, and state-run exchanges do sometimes make last-minute extensions):
- Idaho (December 15; no extension)
- Maryland (December 15; no extension)
- Connecticut (December 15)
- Colorado (January 15)
- Kentucky (January 15)
- Maine (January 15)
- Minnesota (January 15)
- Nevada (January 15)
- New Mexico (January 15)
- Pennsylvania (January 15)
- Washington (January 15)
- Vermont (January 15)
- Massachusetts (January 23)
- California (January 31)
- District of Columbia (January 31)
- Rhode Island (January 31)
- New Jersey (January 31)
- New York (January 31)
Where is ACA enrollment still available for 2021 coverage?
Soon after the open enrollment period for 2021 coverage ended, the Biden administration opened a COVID/American Rescue Plan special enrollment period on HealthCare.gov. This SEP was available for anyone eligible to use the Affordable Care Act’s marketplace, including people who were uninsured as well as those who already had coverage through HealthCare.gov and wanted to pick a different plan. A qualifying event was 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 was available in all of them, but ended in those states on August 15, 2021. However, even after that date, HealthCare.gov is still allowing people to enroll in coverage if they’re eligible for the ARP’s special subsidies for people who have received unemployment compensation in 2021.
In addition, all of the state-run exchanges offered similar COVID-related special enrollment periods in 2021, although some ended earlier and others run longer than the window on HealthCare.gov.
Several state-run exchange (Colorado, Maryland, Nevada, Pennsylvania, Rhode Island, and Washington) ended their COVID-related special enrollment periods on August 15, in line with the scheduled followed by HealthCare.gov. And some had ended theirs earlier in 2021 (Idaho, Massachusetts, and Minnesota). But enrollment in 2021 coverage without a qualifying event, is still ongoing in the following states:
- California: Through December 31
- Connecticut: Through October 31
- DC: Through the end of the pandemic emergency period
- Minnesota: The general COVID-related special enrollment period has ended, but people who have received unemployment compensation in 2021 can still enroll or change to a $0 premium silver plan
- New Jersey: Through December 31
- New York: Through December 31
Who can enroll in ACA-compliant health plans year-round?
Medicaid and CHIP enrollment is available year-round to eligible residents.
Year-round enrollment is also available in the Basic Health Programs in New York and Minnesota. And eligible residents can enroll in the new Covered Connecticut program through the end of December 2021. Enrollment is also available year-round for the ConnectorCare program in Massachusetts, for people who are newly eligible or who haven’t enrolled before.
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.
And CMS has finalized a new rule that allows people with income up to 150% of the poverty level to enroll year-round, as long as the American Rescue Plan’s subsidy enhancements remain in effect. This is currently in place through the end of 2022, but is expected to be extended by Congress.
California, Colorado, and DC have permanently extended ACA open enrollment
As noted above, most of the fully state-run exchanges have extended open enrollment for 2022 coverage until at least January 15, 2022. And some, like New York, have consistently extended open enrollment until the end of January. But three have specifically implemented regulations or legislation to codify an extended open enrollment period:
- 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 2022 health plans will begin November 1, 2021 and will continue through January 31, 2022. California’s enrollment schedule had 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 15 of them as of 2021, and an anticipated 18 as of 2022 — might have experienced 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.
Is Obamacare open enrollment extended through January 15 in all states?
HHS had previously defined open enrollment as the window from November 1 to December 15, but state-run exchanges have had the option to offer special enrollment periods before or after that window, in order to effectively extend open enrollment.
For coverage effective in 2022 and future years, HHS has changed the enrollment window for HealthCare.gov. It’s now November 1 through January 15. But instead of requiring state-run exchanges to use an enrollment window at least that long, HHS is giving them the option of keeping an earlier deadline, as long as it’s not before December 15. So it’s possible that some state-run exchanges might opt for a mid-December deadline, although most are likely to extend their enrollment windows to January 15 or later.
For 2021 enrollments, only Vermont and Maryland opted to keep the December 15 end date, although both states joined the rest of the country in reopening enrollment for 2021 coverage to address the ongoing COVID pandemic and the American Rescue Plan’s new subsidies.
As noted above, New Mexico, Maine, and Kentucky plan to have their own enrollment platforms by the fall of 2021. 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. But now that HHS has extended the HealthCare.gov deadline to January 15, many of the state-run exchanges are likely to use that date rather than issue additional extensions, as most of them tend to end their enrollment windows by mid-January in most years.
Outside of ACA’s open enrollment window, enrollment’s 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/American Rescue Plan special enrollment periods in 2021 are an exception to the normal rules, in that qualifying events were/are not necessary in order to use these enrollment windows.
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.