In this article
- What are qualifying life events?
- 13 Obamacare special open enrollment triggers
- Got a qualifying life event? You'll likely need to provide proof
- Off-exchange special enrollment periods
- Are qualifying events the same for employer-sponsored plans?
- When will coverage take effect if I enroll during a special enrollment period?
- For people already enrolled in the exchange, SEP applies if the plan substantially violates its contract
- Who doesn't need a qualifying life event?
Open enrollment for health insurance plans in the individual market (on- and off-exchange) runs from November 1 to December 15 in most states (starting this year). But even outside of the annual open enrollment window, ACA-compliant plans can still be available to people who experience certain qualifying life events.
What are qualifying life events?
Outside of open enrollment, you can still enroll or switch to a different plan if you have a qualifying life event that triggers your own special enrollment period (SEP) window.
People with employer-sponsored health insurance have long been used to both open enrollment windows and qualifying life events. In the employer group market, plans have annual open enrollment windows when members can make changes to their plans and eligible employees can enroll. Outside of that time frame, however, a qualifying life event is required to enroll or change coverage.
In the individual market, this was not how it worked before 2014 – people could apply for coverage anytime they wanted. But policies were not guaranteed issue in most states,1 so pre-existing conditions meant that some people couldn't get coverage or had to pay more for their policies.
All of that changed thanks to the ACA. Individual health insurance is now quite similar to group coverage. As a result, the individual market now utilizes annual open enrollment windows and allows for special enrollment windows triggered by qualifying life events.
So you could still have an opportunity to enroll in ACA-compliant coverage outside of the open enrollment window if you experience a qualifying life event. Depending on the circumstances, you may have a special open enrollment period – generally 60 days but sometimes there's an additional 60-day window before the event as well – during which you can enroll or switch to a different plan.
13 Obamacare special open enrollment triggers
The qualifying life events that trigger special enrollment periods are discussed in more detail in our extensive guide devoted to qualifying life events and special enrollment periods. But here's a summary:
1. Involuntary loss of other coverage
If you involuntarily lose minimum essential coverage, the coverage loss will trigger a special enrollment period so that you can obtain replacement coverage.
Learn more about the SEP due to loss of other coverage.
2. Your health plan renews at a time other than January 1
It’s common for health plans to have plan years that align with the calendar year, but that’s not always the case for grandmothered and grandfathered plans, or for employer-sponsored plans. If your health plan renews on a date other than January 1, you’ll have a special enrollment period for individual market coverage that will allow you to switch to a new plan instead of renewing your non-calendar-year plan.
Learn more about the SEP for people with non-calendar-year coverage.
3. Becoming a dependent or gaining a dependent
Becoming or gaining a dependent (as a result of birth, adoption, or placement in foster care) is a qualifying life event. And unlike other qualifying life events that trigger SEPs, Coverage can be back-dated to the date of birth, adoption, or placement in foster care.
Learn more about the SEP triggered by birth, adoption, or placement in foster care.
4. Marriage
If you get married, you have a 60-day open enrollment window that begins on your wedding day. However, at least one partner must have had minimum essential coverage (or lived outside the U.S. or in a U.S. Territory) for at least one of the 60 days before the marriage. In other words, you cannot use marriage to gain coverage if neither of you had coverage before getting married.
Learn more about the SEP due to marriage.
5. Divorce (in some state-run exchanges)
Exchanges have the option of granting a special enrollment period for people who lose a dependent or lose dependent status as a result of a divorce or death, even if coverage is not lost as a result. In most states – including the 30 states that use HealthCare.gov – divorce without an accompanying loss of coverage will not trigger a special enrollment period.2
6. Becoming a United States citizen or lawfully present resident
This qualifying life event only applies within the exchanges. Carriers selling coverage off-exchange are not required to offer a special enrollment period for people who gain citizenship or lawful presence in the United States.3
Learn more about the SEP due to becoming a U.S. citizen or gaining lawfully present status.
7. A permanent move
As long as you already had coverage before your move, you’ll have a SEP if you move to an area where different qualified health plans (QHPs) are available.
Learn more about the SEP triggered by a permanent move.
8. An error or problem with enrollment
If the enrollment error (or lack of enrollment, as the case may be) was the fault of the exchange, HHS, or an enrollment assister, a special enrollment period can be granted.
Learn more about the SEP triggered by an enrollment error.
9. Employer-sponsored plan becomes unaffordable or stops providing minimum value
An employer-sponsored plan is considered affordable in 2026 as long as the employee's share of the premium isn't more than 9.9602% of their household income.4
cA plan provides minimum value as long as it covers at least 60% of expected costs for a standard population of people covered by employer-sponsored insurance, and also provides substantial coverage for inpatient and physician services.
If a change in benefits or income results in a person’s employer-sponsored coverage becoming unaffordable or no longer providing minimum value, this will trigger a SEP.
10. An income increase that moves you out of the coverage gap
There are nine states where there is still a Medicaid coverage gap, and almost 1.4 million people are unable to access affordable health coverage as a result.5
11. Gaining access to a QSEHRA or Individual Coverage HRA
QSEHRAs and ICHRAs allow employers to reimburse employees for the cost of individual-market health insurance. Employees who gain access to a QSEHRA or ICHRA will have access to a SEP at that point, so they can obtain individual-market coverage (or switch to a new plan) and take advantage of the benefit offered by their employer.
Learn more about the SEP triggered by an ICHRA or QSEHRA offer.
12. An income or circumstance change that makes you newly eligible (or ineligible) for subsidies or CSR
If you’re enrolled in an exchange plan and your income or circumstances change such that you become newly eligible or newly ineligible for premium tax credits or cost-sharing subsidies, you'll have an opportunity to switch plans. And if you’re enrolled in an off-exchange plan and become newly eligible for subsidies, you can switch to the exchange at that point.
Learn more about the SEP triggered by a change in subsidy eligibility.
13. Various exceptional circumstances
Special enrollment periods can be granted due to certain exceptional circumstances. These can be widespread, due to something like a natural disaster, or they can apply on a case-by-case basis.
Learn more about the exceptional circumstances that can trigger a SEP.
Got a qualifying life event? You'll likely need to provide proof
The requirements for proof of SEP eligibility have changed over time. Most recently, a rule finalized in 2025 calls for additional SEP eligibility verification starting in 2026. But this provision was blocked by a judge in August 2025, pending the outcome of a lawsuit that was still unresolved as of February 2026.6
If the 2025 rule is eventually implemented, it will require more people to provide proof of their qualifying life event, rather than being allowed to simply attest to the qualifying life event.
Here's a brief summary of how these rules have changed over time:
- In February 2016, HHS confirmed that it would begin requiring proof of eligibility to grant special enrollment periods triggered by birth/adoption/placement for adoption, a permanent move, loss of other coverage, and marriage (together, these account for three-quarters of all qualifying life events in Healthcare.gov states).
- The eligibility verification process was further stepped up in 2017, thanks to “market stabilization” rules that HHS finalized in April 2017. Under that rule, the SEP eligibility verification process began to apply to 100% of SEP applications, starting in June 2017.
- By 2022, under the Biden administration, SEP eligibility verification had been scaled back slightly, and applied to 90% of special enrollment period applications. The SEP verification program generated controversy, with some consumer advocates noting that it could further deter healthy people from enrolling when they're eligible for a SEP. And HHS noted that the verification process is harmful to Black applicants, as they are less likely to submit the necessary documentation than white consumers.
- HHS addressed this in the annual rule-change notification for 2023. They removed the SEP verification requirements for all SEPs other than loss of coverage. Loss of coverage does represent the majority of SEP applications, and people using this SEP still have to provide proof of their loss of coverage.7 But pre-enrollment eligibility verification is no longer required on HealthCare.gov for other qualifying life events.
- This was slated to change in 2026, as a result of the rule that was finalized in 2025. But as noted above, this has been blocked by a judge and had not taken effect as of February 2026. If implemented, the rule will allow pre-enrollment eligibility verification for any qualifying life event, rather than just loss of coverage. And the Marketplace will be required to obtain proof of SEP eligibility for at least 75% of new SEP enrollments.8
- If implemented, the new federal rule will apply in states that use HealthCare.gov, but state-run exchanges will continue to set their own rules for SEP eligibility verification.9
Off-exchange special enrollment periods
Most qualifying life events apply both inside and outside the exchanges. There are a few exceptions, however. For policies sold outside the exchanges, there are a few qualifying life events that HHS does not require carriers to accept as triggers for special enrollment periods (however, the carriers can accept them if they wish).
These include gaining citizenship or a lawful presence in the United States or being an American Indian or Alaska Native. (Within the exchanges, American Indians and Alaska Natives can make plan changes as often as once per month, and enrollment runs year-round. American Indians and Alaska Natives are also eligible for enhanced cost-sharing reductions, but only for plans obtained through the exchange.)
In addition, when exchanges grant special enrollment periods based on “exceptional circumstances” those special enrollment periods apply within the exchanges; off-exchange, it's up to the carriers as to whether or not they want to implement similar special enrollment periods.
And carriers tend to have fairly strict rules regarding proof of SEP eligibility. If you're enrolling directly with an insurer, outside of open enrollment, you will need to provide proof of your qualifying life event. (The insurer will let you know what will count as acceptable documentation.)
Are qualifying events the same for employer-sponsored plans?
Although special enrollment period windows are generally longer in the individual market, many of the same life events count as a qualifying life event for employer-based plans and individual-market plans. But some are specific to the individual market under Obamacare.
(For reference, special enrollment period rules for employer-sponsored plans are detailed here. For individual-market plans, they're detailed here and described in more detail in our guide to special enrollment periods.)
When will coverage take effect if I enroll during a special enrollment period?
In almost all cases, coverage takes effect the first of the month after the application is submitted. In the past, many SEPs had a 15th-of-the-month deadline, and applications submitted in the latter half of the month would take effect the first of the second following month. But as of 2022, HealthCare.gov eliminated the requirement that applications be submitted by the 15th of the month to get coverage the first of the following month. And this now applies nationwide.
Coverage can be backdated to the date of the qualifying life event for birth, adoption, placement in foster care, or a court order.3
For people already enrolled in the exchange, SEP applies if the plan substantially violates its contract
A special enrollment period is available in the exchange (only for people who are already enrolled through the exchange) if the insured is enrolled in a QHP that “substantially violated a material provision of its contract in relation to the enrollee.”
This does not mean that enrollees can switch to a new plan simply because their existing carrier has done something they didn't like – it has to be a “substantial violation” and there's an official channel through which such claims need to proceed. It's noteworthy that a mid-year change in the provider network or drug formulary (covered drug list) does not constitute a material violation of the contract, so enrollees are not afforded a SEP if that happens.
Who doesn't need a qualifying life event?
In some circumstances, enrollment is available year-round, without a need for a qualifying life event:
- Native Americans/Alaska Natives – as defined by the Indian Health Care Improvement Act – can enroll anytime during the year. Native Americans/Alaska Natives may also switch from one QHP to another up to once per month (the special enrollment periods for Native Americans/Alaska Natives only apply within the exchanges - carriers selling off-exchange plans do not have to offer a monthly special enrollment period for American Indians).
- Medicaid and CHIP enrollment are also year-round. For people who are near the threshold where Medicaid eligibility ends and exchange subsidy eligibility begins, there may be some “churning” during the year, when slight income fluctuations result in a change in eligibility. If income increases above the Medicaid eligibility threshold, there's a special open enrollment window triggered by loss of other coverage. Unfortunately, in states that have not expanded Medicaid, the transition between Medicaid and QHPs in the exchange is nowhere near as seamless as it would have been if the ACA had been fully implemented in those states.
- In addition to Medicaid/CHIP, some states have other types of coverage that can be obtained outside of open enrollment:
- Basic Health Programs in Oregon, Minnesota, and Washington, DC, and New York's Essential Plan (previously a BHP, now a similar program but with higher income limits, reverting to a BHP in mid-2026).
- The ConnectorCare program in Massachusetts (for people who are newly eligible or who haven’t enrolled before).
- The CoveredConnecticut program for eligible Connecticut residents.
- Employers can select SHOP plans (or small-group plans sold outside the exchange) year-round. But employees on those plans will have the same sort of annual open enrollment windows that applies to any employer group plans.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written hundreds of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
Footnotes
- “Health Insurance Market Reforms: Guaranteed Issue” KFF. June 2012. ⤶
- “Special enrollment opportunities” HealthCare.gov. Accessed July 14, 2025 ⤶
- “Special Enrollment Period Reference Chart” Health Reform Beyond the Basics (Center on Budget and Policy Priorities) Accessed Feb. 3, 2026 ⤶ ⤶
- “Revenue Procedure 2025-25” Internal Revenue Service. Accessed Feb. 3, 2026 ⤶
- “How Many Uninsured Are in the Coverage Gap and How Many Could be Eligible if All States Adopted the Medicaid Expansion?” KFF.org. Feb. 25, 2025 ⤶
- “City of Columbus et al. v. Kennedy et al.” Georgetown Law School O’Neill Institute, Health Care Litigation Tracker. Accessed Feb. 3, 2026 ⤶
- “Federally-facilitated Exchange (FFE) Enrollment Manual” Centers for Medicare & Medicaid Services. Aug. 19, 2024 ⤶
- “Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability” Federal Register, U.S. Department of Health & Human Services. June 25, 2025 ⤶
- “Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability” Federal Register, U.S. Department of Health & Human Services. June 25, 2025 ⤶
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