Availability of short-term health insurance in Washington

No. The Washington Office of the Insurance Commissioner confirmed in September 2022 that there were no longer any insurers offering short-term health insurance in Washington, and that is still true as of 2024.

That may or may not change in the future. It’s possible that other insurers might start offering short-term plans in the state, but they would have to conform to the state’s fairly strict rules (described below).

The current rules for short-term health insurance in Washington State, went into effect in January 2019. They limit short-term plan duration to no more than three months and prohibit renewals. Previously, the duration of short-term coverage in Washington State was not restricted beyond federal regulations, although such plans had to officially be determined to be short-term limited-duration plans by the Insurance Commissioner and approved prior to being offered for sale. (See RCW 48.43.005 (26)(l).)

Until October 2, 2018, federal regulations limited short-term health plans to no more than three months, and renewals were prohibited. But the Trump administration’s rules for short-term plans (effective October 2, 2018) allow them to have initial terms of up to 364 days, and a total duration (including renewals) of up to 36 months.³

For short-term health plans sold or issued on or after Sept. 1, 2024, new federal rules will limit initial terms to no more than three months. Total duration, including renewals, will be capped at four months. But since Washington already has stricter rules, with duration limited to three months, the federal rules will not be applicable in Washington.

Consumers in Washington can buy ACA-compliant health insurance through the state’s Marketplace, Washington Healthplanfinder. Twelve carriers offer coverage through the exchange in 2024, and 11 of them have filed rates and plans for 2025 coverage. (In addition, two insurers only offer coverage outside the exchange, meaning subsidies cannot be used with their plans.)⁴

ACA-compliant plans are purchased on a month-to-month basis, so you can enroll in coverage even for only a few months until another policy takes effect – and if you’re eligible, you may qualify for financial assistance in the form of a premium subsidy.

Washington residents may also be eligible for Medicaid coverage.

The relaxed federal regulations implemented by the Trump administration in 2018 (allowing short-term plans to have longer durations) are clear in noting that states may impose tighter regulations. And Washington’s insurance commissioner, Mike Kriedler,  announced in March 2018 that his office would begin the process of rule-making to define short-term plans at the state level, which resulted in the current rule in Washington going into effect in January 2019.⁵

An outline of the proposed regulations was published in June 2018. The official draft regulation notice was published on August 21, 2018, and public comments were accepted until September 24, 2018.

The rule was officially adopted in October 2018. It was adopted as proposed, except the rule requiring 20 days’ notice before a rescission or cancellation was adjusted for circumstances in which there are fewer than 20 days remaining in the plan’s duration.

The current regulations, which took effect in January 2019, include the following provisions:

• Short-term plans are limited to three months in duration with no renewals allowed.
• Insurers are prevented from selling short-term plans to an applicant who had already had three months of short-term coverage in the prior 12 months.
• Short-term plans are required to cover a list of basic inpatient, outpatient, and surgical services.
• Short-term plans must continue coverage (with no additional premiums) if the insured is hospitalized on the date that the short-term plan would otherwise have ended. The extension of coverage would last until the patient is discharged from the hospital.
• The lookback period for pre-existing conditions is limited to no more than 24 months (i.e., a pre-existing condition that hadn’t had symptoms or treatment for more than 24 months cannot be excluded).
• A short-term insurer must offer at least one plan with a per-person deductible of $2,000 or lower.
• The sale of short-term plans is banned during the open enrollment window that applies to ACA-compliant plans, if the short-term coverage is to take effect in January or February. So short-term plans can’t be sold in direct competition with ACA-compliant plans during open enrollment. State regulators noted that this is to help avoid confusion for consumers, since short-term plans purchased during open enrollment would take effect before the start of the new year, whereas ACA-compliant plans sold during open enrollment would take effect January 1 of the coming year. (Open enrollment for ACA-compliant plans in the individual market now runs from Nov. 1 to Jan. 15, and Washington’s rules have been updated to align with this).

As noted above, there were short-term plans available in the state until mid-2022. But since then, there have not been any short-term plans available.