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States Expand Individual Market Open Enrollments Due to COVID-19

In response to the COVID-19 emergency, many states are mandating an extension of the open enrollment period for individual health care coverage. Uninsured individuals may now have an opportunity to seek health care coverage.

Background:

Under the Affordable Care Act, individual health care coverage is limited to an annual open enrollment. To enroll for coverage in 2020, individuals need to apply between November 1 and December 15, 2019. If individuals do not enroll during this window, they may only apply if they qualify for a special enrollment period (SEP). As long as an individual enrolls within 60 days of one of these qualifying SEP events, they may enroll outside of the annual open enrollment affording them coverage mid-year.

SEPs exist in most markets for the following circumstances:

  • Loss of employer-sponsored health coverage;
  • COBRA coverage ending once the maximum time period expires;
  • Changes in marital status, e.g. marriage, divorce;
  • Change in dependent status, e.g. birth, adoption;
  • Loss of Medicaid, CHIP, or Medicare coverage;
  • Losing coverage through a family member;
  • Employer’s offer to help with insurance premium through an Individual Coverage HRA (ICHRA or QSEHRA);
  • Becoming a US citizen; or
  • Leaving incarceration

New Developments:

With the advent of COVID-19, many states are addressing the need for uninsured individuals to seek testing and treatment and do not want the lack of health care coverage to be a barrier. Therefore, many states are contemplating, or are enacting, limited open enrollment extensions to allow uninsured residents of their state to apply for coverage. Currently, most state-based exchanges are offering the extended open enrollment for effective dates beginning April 1, 2020. The federal exchange along with state-based exchanges using the federal portal are contemplating this additional coverage. Many of the expansions apply to coverage both on and off the exchange.

Reference the complete list of the states and their expansion of coverage, below. Remember: coverage is available in all states if the individual loses their health coverage or qualifies under any other SEP. These extensions are just for those who are uninsured and missed this year’s open enrollment.

Exchange Special Enrollment Periods

State Exchange Type New SEP Due to COVID-19 New SEP Expansion Dates New Eligibility Rules Website/Enrollment
AK State w/ federal portal No Healthcare.gov
AL Federal No Healthcare.gov
AR Federal No My Arkansas Insurance
AZ State No Healthcare.gov
CA State Yes 3/20/20 – 6/30/20 May now apply if uninsured and eligible Covered California
CO State Yes 3/20/20 - 4/3/20 Those who are currently uninsured or about to lose coverage due to COVID-19 for 4/1/20 effective date Connect for Health Colorado
CT State Yes 3/19/20 - 4/2/20 Uninsured, if lawfully present and not incarcerated Access Health CT
DC State Yes Anyone who is uninsured, coverage begins the first of the month following enrollment DC Health Link
DE Federal No Healthcare.gov
FL Federal No Healthcare.gov
GA Federal No Healthcare.gov
HI Federal No Healthcare.gov
IA Federal No Healthcare.gov
ID State No Your Health Idaho
IL Federal No Healthcare.gov
IN Federal No Healthcare.gov
KS Federal No Healthcare.gov
KY State w/ federal portal No
Kentucky Health Benefit Exchange
LA Federal No Healthcare.gov
MA State Yes 3/11/20 - 4/25/20 Uninsured residents of MA. Additionally, individuals with coverage as of 3/18/20 will not lose coverage until one month after the emergency period ends unless they request it or are no longer a resident of MA. Massachussetts Health Connector
MD State Yes 3/16/20 - 4/15/20 Uninsured Marylanders for an April 1 effective date Maryland Health Connection
ME Federal No Healthcare.gov
MI Federal No Healthcare.gov
MN State Yes 3/23/20 - 4/21/20 Uninsured Minnesotans who do not have health insurance MNsure
MO Federal No Healthcare.gov
MS Federal No Healthcare.gov
MT Federal No Healthcare.gov
NC Federal No Healthcare.gov
ND Federal No Healthcare.gov
NE Federal No Healthcare.gov
NH Federal No Healthcare.gov
NJ State w/ federal portal No Get Covered New Jersey
NM State w/ federal portal No Be Well New Mexico
NV State Yes 3/17/20 - 4/15/20 Individuals who are not, or who have not been, enrolled in On-Exchange for any of 2020 Nevada Health Link
NY State Yes 3/16/20 - 4/15/20 Eligible individuals for effective date of April 1, 2020 NY State of Health
OH Federal No Healthcare.gov
OK Federal No Healthcare.gov
OR State w/ federal portal No Oregon Healthcare.gov
PA State w/ federal portal No Pennsylvania State-Based Exchange
RI State Yes Thru 4/19/20 Uninsured, qualified individuals HealthSource RI
SC Federal No Healthcare.gov
SD Federal No Healthcare.gov
TN Federal No Healthcare.gov
TX Federal No Healthcare.gov
UT Federal No Healthcare.gov
VA Federal No Healthcare.gov
VT State Yes Additional 30 days Uninsured residents. Additionally, will extend coverage periods until after the emergency ends and suspending certain terminations Vermont Health Connect
WA State Yes Through 4/8/20 Uninsured, qualified individuals Washington Health Plan Finder
WI Federal No Healthcare.gov
WV Federal No Healthcare.gov
WY Federal No Healthcare.gov

For more information on evolving compliance regulations in the wake of the COVID-19 pandemic, visit our OneDigital Coronavirus Advisory Hub, or reach out to your local OneDigital advisory team.

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