COVID/ARP-Related Special Enrollment Period for 2021 Health Insurance

Opportunity to Get or Change Coverage

Two women smiling and hugging
To respond to the COVID-19 pandemic, a special enrollment period for health insurance has been opened in most states.

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Although individual/family health insurance is normally only available for purchase (or plan changes) during the annual open enrollment period in the fall or when a person experiences a qualifying event, that is not the case in 2021. Instead, enrollment is open in most states until mid-August.

The fact that 26 million Americans have no health insurance has been among the challenges the United States has faced in dealing with the COVID-19 pandemic. To address this, the Biden administration announced in January 2021 that a one-time special enrollment period would be opened on HealthCare.gov (the federally-run marketplace/exchange), running from February 15, 2021, to May 15, 2021. And soon after the American Rescue Plan (ARP) was enacted in March 2021, the Biden administration announced that the enrollment window would be extended another three months, through August 15, 2021, in order to allow people to take advantage of the additional financial assistance provided by the ARP.

The District of Columbia and 14 states run their own exchanges instead of using HealthCare.gov. But all of them have also opened up special enrollment periods to address COVID and the ARP, although the specific details vary by state.

Executive Order Opens Enrollment Period

The initial announcement of the special enrollment period came just hours after President Biden signed an executive order designed to strengthen Medicaid and the Affordable Care Act; the executive order directed federal agencies to consider a wide range of changes and improvements, including a special enrollment period.

Most of the changes mentioned in the executive order will have to go through the federal rulemaking process and could take months to come to fruition. But the decision to open a special enrollment period on HealthCare.gov was immediate.

Throughout 2020, various stakeholders, including insurers and several states that use HealthCare.gov (the federally-run marketplace/exchange) asked the Trump administration to open a COVID-related special enrollment period on HealthCare.gov, but the administration declined to do so.

Normal special enrollment windows were available throughout the year, however, for people who experienced qualifying events such as the loss of employer-sponsored health coverage.

Outreach to the Uninsured

HealthCare.gov's open enrollment period for 2021 health coverage ran from November 1, 2020, to December 15, 2020, giving people an opportunity to have coverage in place as of the start of 2021. But as was the case for the past few years, federal funding for outreach, marketing, and enrollment assistance was sharply lower than it had been prior to 2017.

After the enrollment window ended, there were still millions of uninsured Americans—many of whom are unaware of the financial assistance available via the marketplace—who would be eligible for free coverage if they applied. Free plans are available if an enrollee's premium subsidy would be sufficient to fully cover the cost of the plan they select. And because the American Rescue Plan has increased subsidy amounts, free coverage has become even more widely available.

So in addition to opening a special enrollment period, the Biden administration is spending $50 million on outreach, with "a mix of tactics to increase awareness, including advertisements on broadcast, digital, and an earned media."

Even though the COVID-related special enrollment period started just two months after the general open enrollment period ended, the additional federal funding for outreach and enrollment assistance is expected to reach some people who simply weren't aware of their coverage options prior to the start of 2021.

And enrollment is certainly outpacing the normal rate of enrollment we'd see during the same time period in a normal year. During the first several weeks of the enrollment window, from February 15 to March 31, CMS reported that more than 528,000 people had enrolled through HealthCare.gov, which was about 2.5 times the normal pace of enrollment at that time of year. This was before the American Rescue Plan's additional subsidy amounts had been deployed on HealthCare.gov, but it's important to note that a qualifying event is not necessary in order to enroll during the COVID/ARP window in 2021, whereas a qualifying event would normally be necessary in order to enroll outside of the annual enrollment window in the fall.

Who Is Eligible to Enroll?

The executive order that President Biden signed in late January clarified that HHS should consider a special enrollment period "for uninsured and under-insured Americans." The concept of "under-insured" is open to interpretation, and the administration opted to err on the side of simply making the enrollment window available to as many people as possible. Most—but not all—of the state-run exchanges have also taken this approach, essentially treating the COVID/ARP-related enrollment window as an open enrollment period.

The federally-run COVID/ARP enrollment period is available to anyone eligible to enroll in a plan through HealthCare.gov, including people who are currently uninsured (or covered under a plan that isn't considered minimum essential coverage, such as short-term health insurance or a healthcare sharing ministry plan) as well as people who are already enrolled in a plan through HealthCare.gov.

HHS confirmed that people who are already enrolled in a plan through HealthCare.gov can use the COVID-related special enrollment period "to change to any available plan in their area without restriction to the same level of coverage as their current plan."

This is important, as normal special enrollment period rules (i.e., when special enrollment periods are triggered by qualifying events) mostly only allow current enrollees to switch to another plan at the same metal level, with unrestricted plan changes only available during the annual open enrollment period.

But the enrollment window that's being offered on HealthCare.gov from February 15 to August 15, 2021 is much more flexible, and is more like an open enrollment period than a normal special enrollment period. People do not need a qualifying event in order to enroll, and the window can be used for new enrollments as well as plan changes.

People who are considering a plan change during this window need to keep in mind that mid-year plan changes generally mean starting over at $0 on the new plan's deductible and out-of-pocket maximum. This is important to keep in mind if you've already incurred some out-of-pocket costs so far this year, as they will not transfer to a new policy if it's offered by a different insurance company. Many insurers have agreed, however, to allow carry-over credits for out-of-pocket expenses if enrollees switch to a different plan offered by their current insurer.

So if you've already incurred some out-of-pocket expenses in 2021 and are considering a plan change to better take advantage of the ARP's additional subsidies, you'll want to check with your insurer to see if they'll credit the amount you've spent towards another plan they offer.

State-Based Exchanges Follow Suit

HealthCare.gov is the exchange/marketplace in 36 states, and the February 15 to August 15 COVID/ARP-related special enrollment period is available in all of them, allowing anyone eligible to use the marketplace in those states to enroll or change their coverage.

The District of Columbia and the other 14 states run their own exchanges, but all of them have also opted to offer COVID-related special enrollment periods that align fairly closely with the window that's being offered on HealthCare.gov. But a few have more restrictive rules in terms of who can enroll or make a plan change, and some have different deadlines. The state-run exchanges have the following dates and rules for their COVID/ARP-related special enrollment periods:

  • California: Anyone eligible to enroll can do so until December 31, 2021.
  • Colorado: Anyone eligible to enroll can do so until August 15, 2021.
  • Connecticut: Anyone eligible to enroll can do so between May 1 and August 15, 2021.
  • District of Columbia: Anyone uninsured can enroll anytime until the end of the COVID emergency period in DC. DC is also offering a separate enrollment window to people who want to take advantage of the ARP's subsidy enhancements.
  • Idaho: Anyone eligible to enroll can do so until April 30, 2021.
  • Maryland: Uninsured residents can enroll anytime until August 15. Unlike other states, retroactive coverage is available, depending on when a person applies for coverage.Existing enrollees with bronze or catastrophic plan can upgrade their coverage, but Maryland is not allowing the same level of plan-change flexibility that most other states are offering.
  • Massachusetts: Anyone eligible to enroll can do so until July 23.
  • Minnesota: Anyone not currently enrolled through MNsure (the marketplace in Minnesota) can enroll until July 16, 2021.
  • Nevada: Anyone eligible to enroll can do so until August 15, 2021.
  • New Jersey: Anyone eligible to enroll can do so until December 31, 2021.
  • New York: Anyone eligible to enroll can do so until December 31, 2021.
  • Pennsylvania: Anyone eligible to enroll can do so until August 15, 2021.
  • Rhode Island: Anyone eligible to enroll can do so until August 15, 2021.
  • Vermont: Uninsured residents can enroll until May 14. People enrolled off-exchange (directly through an insurer) can also switch to the exchange.
  • Washington: Anyone eligible to enroll can do so until August 15, 2021.

Some of these windows could end up being further extended at a later date, giving residents an additional opportunity to enroll or make a plan change for 2021, even if they don't have a qualifying event. But after the COVID/ARP-related enrollment windows ultimately end, enrollments and plan changes will be limited to people who experience qualifying events, until open enrollment starts again in November 2021, for coverage effective in January 2022.

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Article Sources
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