Chapter 8: Do you have to enroll through an exchange? (The Insider’s Guide to Obamacare’s Open Enrollment 2016-2017)

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Chapter 8: Insider’s Guide to Obamacare’s Open Enrollment

Do you have to enroll through an exchange?

No. You don’t have to buy your health coverage through an exchange, but if you don’t, you be may missing out on significant cost savings

  • By
  • contributor
  • August 21, 2016

The Insider's Guide to Obamacare's Open Enrollment 2016-2017 EditionOne of the primary provisions of the Affordable Care Act was to overhaul the individual health insurance market. The law eliminated medical underwriting, gender-based premiums, and skimpy policies with exorbitant out-of-pocket exposure, and it’s narrowed the premium gap between younger and older insureds. Lifetime and annual benefit maximums have also been eliminated.

Buying a policy in the individual market is now a realistic option for a lot more people. And the health insurance exchanges in each state are the mechanism that makes it easy to compare policies, enroll in a plan and receive a subsidy (if you’re eligible).

But they’re not the only way to enroll. Although much of the media attention on individual health insurance has focused on the exchanges, individual health insurance policies are also available off-exchange and may be a good choice for some consumers.

An off-exchange plan is simply a health insurance policy that is purchased directly from the carrier or through an agent or broker, outside of the state health insurance exchange. In addition to the roughly 11 million people with in-force individual coverage through the exchanges, the Congressional Budget Office estimates that 9 million people will purchase individual health insurance outside the exchanges in 2016.

Identical consumer protections outside off-exchange

The consumer protections in the ACA apply to all individual major medical policies, regardless of whether the coverage is sold in the exchange. In other words, if you want to get coverage outside of the exchange, you still have access to ACA-compliant health insurance policies.

In addition to the basic requirements to which all policies must now adhere in order to be deemed ACA-compliant, plans that are sold in the exchanges must also be certified as qualified health plans (QHPs).

QHP certification is granted by the exchanges, and can vary from one state to another. Exchanges can, in fact, set QHP requirements that exceed the basic guidelines of the ACA. (Pages 33-38 of this HHS brief explain why.) So although all of the major medical plans sold in the individual market have to meet ACA requirements, QHPs may need to comply with additional standards that vary from one state to another. QHP issuers in all states must offer at least one Gold plan, one Silver plan and one child-only plan.

But that doesn’t mean QHPs can’t also be sold off-exchange. Some carriers are selling their certified QHPs both on and off exchange (with all enrollees in the same pool for risk-sharing purposes) – but policies sold off exchange don’t have to be certified as QHPs. They are still good quality plans, though; the days of Swiss-cheese coverage are over, regardless of how policies are purchased. And off-exchange plans are guaranteed issue regardless of medical history, just like policies in the exchanges.

A few important notes

  • The exchange is the best option for people who qualify for premium subsidies and cost-sharing subsidies, as subsidies are only available for plans purchased in the exchanges.
  • If you begin the year with an income that isn’t subsidy eligible and then your income drops during the year to a level that would make you eligible for a subsidy, you would only be able to start getting a subsidy at that point if you were already enrolled in an exchange plan.
  • If you opt for an off-exchange plan during open enrollment, you won’t be able to switch to a subsidy-eligible exchange plan until the next open enrollment, regardless of any mid-year changes in your income.
  • If you have a qualifying event that triggers a special enrollment period, you’ll be able to switch to an exchange plan. But again, a change in income is not a qualifying event, unless you’re already enrolled in an exchange plan. And a few qualifying events only apply to people who are already enrolled in a plan through the exchange (ie, those folks would have an opportunity to switch to a different exchange plan, but people enrolled in off-exchange plans wouldn’t have any leeway to switch plans if they experience a qualifying event that only applies to people already enrolled in the exchange).

One noticeable difference in benefits

Pediatric dental – one of the ACA’s essential health benefits – could also play a role in your decision. In most states, you can purchase coverage in the exchange that does not include pediatric dental, as long as the exchange offers stand-alone dental plans. (There are some exceptions: some states require pediatric dental to be embedded in all health plans; in some cases, carriers have simply opted to embed pediatric dental; and in some states, pediatric dental is sold as stand-alone coverage but cannot be waived – the specifics vary considerably from one state to another).

But off-exchange, you cannot avoid purchasing pediatric dental (although you should be able to get a zero-premium pediatric dental plan if you don’t have children). For some enrollees, this is a compelling reason to shop in the exchange.

Pricing and benefits

If the same policy is sold on and off-exchange, the price will be the same. Some carriers opt to sell identical plans both inside the exchange and outside the exchange. (Some carriers are only offering plans outside the exchange, so you’ll need to shop off-exchange in order to see their plans.)

But carriers can choose to offer different plan designs or networks for their on-exchange plans and their off-exchange plans. If a carrier is offering plans outside the exchange that are different from the plans they offer inside the exchange, the pricing will be different, too.

In some states, the “best” coverage is off-exchange; in others, it’s on the exchange. In some states, the cheapest plan is off-exchange, and in others, it is on the exchange.

There’s no one answer that applies everywhere in terms of whether it’s better to get an exchange plan or an off-exchange plan.


If you want to shop off-exchange, you can purchase a policy directly from a health insurance carrier, or from an agent or broker. Again, the price will be the same either way. Even if you know that you won’t qualify for subsidies in the exchange, you’ll want to consider exchange options as well as off-exchange plans to find the policy that best meets your needs.

Brokers who are certified to sell exchange policies should be able to provide you with both on and off-exchange options, all in one place. (You can call one of’s partners at 1-844-608-2739 to talk with a licensed, exchange-certified brokers who can enroll you in an ACA-compliant plan.)

Be aware that the open enrollment window for individual health insurance applies both on and off-exchange, so either way, you’ll need to purchase a policy between November 1, 2016 and January 31, 2017. Otherwise, you’ll have to wait until the 2018 open enrollment begins in November 2017, unless you have a qualifying event.

In the District of Columbia, there are no off-exchange plans. All individual and small group plans in DC have to be purchased through DC Health Link. In 2014 and 2015, Vermont also mandated that all plans had to be purchased through Vermont Health Connect, but direct-to-carrier enrollment (ie, off-exchange enrollment) became available in Vermont in 2016.

Decisions, decisions

If you qualify for a subsidy, stick with the exchange. But if you don’t, take your time, compare all of the options, and then apply for the policy that makes the most sense for your situation. Disregard politically motivated advice from people who have a vested interest in directing you either onto the exchange or away from it.

The ACA has improved the quality of coverage in the individual market and has also expanded the options that are available for many people, thanks to guaranteed issue coverage and subsidies. Even though the exchanges are a heavily publicized part of the ACA, the improvements from the law extend to off-exchange plans as well. Consumers can feel confident regardless of which option they choose.