Compliance Confidence
States Expand Individual Market Open Enrollments Due to COVID-19
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.
Share
Related News & Updates

Article
IRS Issues Final Rule to Fix “Family Glitch”
10.12.2022