COVID-Related Special Enrollment Period for 2021 Health Insurance

Opportunity to Get or Change Coverage

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

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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 has opened a one-time special enrollment period on HealthCare.gov (the federally-run marketplace/exchange), running from February 15, 2021, to May 15, 2021. And all of the states that run their own exchanges have followed suit, although the specific details vary by state.

Executive Order Opens Enrollment Period

The 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 directs 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.

There are 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.

They could get a plan for free because their premium subsidy would be sufficient to fully cover the cost of the least expensive plans available; they may be much better off, however, with a better plan that does have at least some monthly premium.

So in addition to opening a special enrollment period, the Biden administration plans to spend $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 starts 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.

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 has opted to err on the side of simply making the enrollment window available to as many people as possible.

The special 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 health care sharing ministry plan) as well as people who are already enrolled in a plan through HealthCare.gov.

HHS has 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 May 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 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.

State-Based Exchanges Follow Suit

HealthCare.gov is the exchange/marketplace in 36 states, and the February 15 to May 15 COVID-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 (although some are limiting enrollment only to people who are uninsured, or who don't already have coverage through the exchange, and some have different deadlines). The state-run exchanges have the following dates and rules for their COVID-related special enrollment periods:

  • California: Anyone eligible to enroll can do so between February 1 and May 15.
  • Colorado: Anyone not currently enrolled in an ACA-compliant plan can enroll between February 8 and May 15.
  • Connecticut: Anyone not already enrolled in a plan through the exchange can enroll between February 15 and March 15.
  • District of Columbia: Anyone uninsured can enroll anytime until the end of the COVID emergency period in DC.
  • Idaho: Uninsured residents can enroll between March 1 and March 31, with coverage effective April 1.
  • Maryland: Uninsured residents can enroll anytime until May 15. Unlike other states, retroactive coverage is available, depending on when a person applies for coverage.
  • Massachusetts: Anyone eligible to enroll can do so until May 23.
  • Minnesota: Anyone not currently enrolled through MNsure (the marketplace in Minnesota) can enroll between February 16 and May 17.
  • Nevada: Anyone who isn't currently enrolled through the exchange (Nevada Health Link) can enroll anytime between February 15 and May 15.
  • New Jersey: Anyone eligible to enroll can do so until May 15.
  • New York: Uninsured residents can enroll anytime until March 31.
  • Pennsylvania: Anyone can enroll between February 15 and May 15.
  • Rhode Island: Uninsured residents can enroll anytime until May 15.
  • Vermont: Uninsured residents can enroll between February 16 and May 14.
  • Washington: Anyone not already enrolled in a plan through the exchange can enroll between February 15 and May 15 

Some of these windows could end up being further extended at a later date (Connecticut's announcement, for example, specifically notes that the exchange will determine whether an extension is warranted as they get closer to the March 15 deadline that they've currently set). But for the time being, all uninsured residents can still enroll in coverage for 2021 with a March 1 or April 1 effective date (or a later effective date if they enroll in April or May, which is an option available in most states), even if they don't have a qualifying event.

After the COVID-related enrollment windows end, enrollments and plan changes will be limited to people who experience qualifying events, until open enrollment starts again in November 2021.

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Article Sources
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