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

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.