Key takeaways
- Open enrollment for 2022 coverage ended in most states on January 15, 2022.
- Open enrollment is still ongoing in New York in March.
- 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 (there are now 18 of them) have always had the flexibility to make OEP longer.
- Outside of open enrollment, you normally need a qualifying event to enroll.
- The open enrollment windows have varied over the years.
Q. What is the deadline to enroll in 2022 ACA-compliant health insurance coverage in the individual market?
A. Open enrollment for 2022 health coverage started nationwide on November 1, 2021 (in New York, it began on November 16). In most states, it ended on January 15, 2022 (and in most states, enrollments completed between December 16 and January 15 took effect February 1).
The January 15 end date includes a one-month extension that was added by the Biden administration. For the past several years, open enrollment had 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 have fully state-run exchanges, joining the 15 that already operated as of 2021. So there are 18 fully state-run exchanges that had the option to set an open enrollment deadline other than January 15.
Several of them did so, but most of those enrollment windows closed by the end of January. Maryland’s open enrollment period was extended through the end of February due to the Omicron COVID surge. And New York has opted to extend open enrollment for 2022 coverage through the end of the COVID public health emergency.
As noted below, DC has extended a special enrollment period for uninsured residents through the end of the District’s COVID public health emergency. But as of March 2022, New York is the only state where general open enrollment for 2022 coverage is ongoing.
In the rest of the country, open enrollment ended in January (or mid-December, in the case of Idaho), and enrollments now require proof of a qualifying life event. This includes the 33 states that use HealthCare.gov, as well as the rest of the state-run exchanges: Idaho, Connecticut, Maine, Minnesota, Nevada, New Mexico, Pennsylvania, Washington, Vermont, Massachusetts (open enrollment ended January 23 in Massachusetts), and California, the District of Columbia, Kentucky, Rhode Island, and New Jersey (in those last five, open enrollment ended January 31).
Although these are not an extension of full open enrollment, there are some widespread opportunities to obtain coverage in some areas:
- In Colorado, open enrollment ended January 15, but a special enrollment period runs through March 16 for uninsured residents affected by COVID or the Marshall Fire, with coverage effective the first of the month following enrollment.
- In the District of Columbia, where open enrollment ended January 31, there’s an ongoing special enrollment period for uninsured residents, which continues through the end of DC’s COVID public health emergency period.
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. 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 might be extended by Congress. This special enrollment period is optional for state-run exchanges, although several of them had already rolled it out as of early 2022. This special enrollment opportunity will be available on HealthCare.gov by late March 2022, but was available as of February for people who used the HealthCare.gov call center to enroll.
California, Colorado, and DC have permanently extended ACA open enrollment
As noted above, most of the fully state-run exchanges 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 began November 1, 2021, and continues 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 period 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. After HHS extended open enrollment for HealthCare.gov states through January 15 (starting with the 2022 plan year), Colorado updated its regulations to clarify that open enrollment simply runs from November 1 through 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. DC has also announced that enrollment will continue to be available through the end of the pandemic emergency period. COVID-related special enrollment periods were widespread for much of 2021, and continued through the end of 2021 in a few states. But DC’s blanket extension is the longest in the nation.
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.
Does Obamacare open enrollment continue 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 has given them the option of keeping an earlier deadline, as long as it’s not before December 15. This is why Idaho was allowed to implement a December 22 deadline for enrollment in 2022 coverage. But all of the rest of the state-run exchanges opted to extend their enrollment deadlines to January 15 or later.
As noted above, New Mexico, Maine, and Kentucky now have their own enrollment platforms, bringing the number of fully state-run exchanges to 18. 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 for 2022 and future years, many of the state-run exchanges are using that date rather than issuing additional extensions.
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.
Open enrollment schedule has varied over time
Although open enrollment is now set at November 1 – January 15 in most states, it has varied quite a bit over the years. In the federally-run marketplaces, the following enrollment windows have been used (with some last-minute extensions, and with somewhat different schedules used by the state-run marketplaces):
- 2014 coverage: October 1, 2013 through March 31, 2014
- 2015 coverage: November 15, 2014 through February 15, 2015
- 2016 coverage: November 1, 2015 through January 31, 2016
- 2017 coverage: November 1, 2016 through January 31, 2017
- 2018 coverage: November 1, 2017 through December 15, 2017
- 2019 coverage: November 1, 2018 through December 15, 2018
- 2020 coverage: November 1, 2019 through December 15, 2019
- 2021 coverage: November 1, 2020 through December 15, 2020
- 2022 coverage: November 1, 2021 through January 15, 2022
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.