What are the deadlines for the ACA’s open enrollment period?

Q. What is the deadline to enroll in 2021 health insurance coverage in the individual market? What about 2022 coverage?

A. In most states, open enrollment for 2021 health plans ended on December 15, 2020 (as described below, the Biden administration has proposed a permanent 1-month extension, starting with the enrollment period that begins in the fall of 2021).

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.

It continues through August 15, 2021, and is available for anyone who is eligible to use the Affordable Care Act’s 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 end earlier and others run longer than the window on HealthCare.gov:

• California: Through December 31
• Colorado: Through “at least” August 15
• Connecticut: Through August 15
• DC: Through the end of the pandemic emergency period
• Maryland: Through August 15 (retroactive coverage is available, depending on when a person enrolls)
• Nevada: Through August 15
• New Jersey: Through December 31
• New York: Through December 31
• Pennsylvania: Through August 15
• Rhode Island: Through August 15
• Vermont: Through October 1 for uninsured residents; Through August 15 for people who want to change plans
• Washington: Through August 15

The other three fully state-run exchanges also implemented COVID-related special enrollment periods in 2021, but they have since ended:

• Idaho: Through April 30 (ended; a qualifying event is now necessary in order to enroll or change plans for 2021)
• Massachusetts: Through July 23 (ended; a qualifying event is now necessary in order to enroll or change plans for 2021)
• Minnesota: Through July 16 (this window has ended, but people who have received unemployment compensation in 2021 can still enroll or change to a $0 premium silver plan)

Outside of open enrollment, plan changes and new enrollments are normally only possible for people who experience a qualifying event, but the COVID/American Rescue Plan 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 will start again on Nov. 1, 2021, but a COVID/American Rescue Plan enrollment window continues until August 15, 2021

In the following states, open enrollment for 2021 coverage ended on December 15, and open enrollment for 2022 coverage will start again on November 1, 2021.

But enrollment in 2021 plans is still possible, without a qualifying event, until August 15, 2021. During this extra window, people can enroll in coverage for 2021 or switch to a different plan if it better fits their needs or allows them a better opportunity to take advantage of the American Rescue Plan’s additional subsidies:

• Alabama
• Alaska
• Arizona
• Arkansas
• Delaware
• Florida
• Georgia
• Hawaii
• Illinois
• Indiana
• Iowa
• Kansas
• Kentucky
• Louisiana
• Maine
• Maryland
• Michigan
• Mississippi
• Missouri
• Montana
• Nebraska
• New Hampshire
• New Mexico
• North Carolina
• North Dakota
• Ohio
• Oklahoma
• Oregon
• South Carolina
• South Dakota
• Tennessee
• Texas
• Utah
• Virginia
• West Virginia
• Wisconsin
• Wyoming

California, Colorado, and DC: Open enrollment 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 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.

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, and this tends to be the case most years.

Vermont and Maryland were the only states with fully state-run exchanges where open enrollment for 2021 coverage was not extended. For 2022 coverage, New Mexico, Maine, and Kentucky plan to have a fully state-run exchange, so there will be 18 fully state-run exchanges that have the option to extend open enrollment.

Biden administration proposes extended open enrollment window for 2022 coverage and future years

In June 2021, HHS proposed an extended open enrollment period, starting with the open enrollment window that begins November 1, 2021. The proposal calls for open enrollment to start November 1 and continue through January 15, instead of ending in mid-December. Enrollees would still have to apply by December 15 in order to have coverage effective January 1; applications submitted between December 16 and January 15 would take effect February 1.

If finalized, this window would apply nationwide. But states that run their own exchanges would still have the option to further extend open enrollment, if they want it to continue past mid-January. Most of the fully state-run exchanges do tend to extend open enrollment each year, but few of them go past January 15; this would likely be the default deadline adopted by most of them.

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.

HHS has defined open enrollment as the window from November 1 to December 15, and that applies in every state (as noted above, if HHS extends the deadline to January 15, that would apply 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 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 if CMS extends the general 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 are not necessary in order to use these enrollment windows.

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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.