It’s Open Enrollment Time, So What’s Different This Year?

Open Enrollment

Main Points

  • Open enrollment for 2022 coverage started November 1, 2021. It will close in most states on January 15. However, people must enroll before December 15 to be eligible for coverage effective January 1.
  • Most of them set the end date for open enrollment in this year’s state-run exchanges at January 15 or 31.
  • Enrollment for 2021 plans is available through several state-run exchanges. People who have been paid unemployment compensation in 2021 may still enroll.
  • California, Colorado, Washington, DC, and Washington, DC have extended open enrollment for a permanent period. Most state-run exchanges also tend to offer open enrollment every year. There has been a shift towards fully-state-run exchanges.
  • Fully state-run exchanges (15 for 2021; increasing to 18 by 2022) could always extend OEP.
  • You will normally need to have a qualifying event to enroll, except for open enrollment.

When Is The Last Day To Sign Up For 2022 ACA-Compliant Individual Insurance Coverage? Is 2021 Coverage Still Available?

Open enrollment for 2022 health coverage began nationwide on November 1, 2021. It will be ending in most states on January 15, 2022. However, enrollments must be complete by December 15 to have coverage effective January 1. Therefore, enrollments made between December 16-January 15 will not be covered until February 1.

Biden administration has added a one-month extension to the January 15 deadline. Open enrollment has been closed for several years on December 15. However, the January 15 deadline will now be applied.

When Is Obamacare’s Open Enrollment Deadline For State-Run Exchanges In The United States?

New rules clarify that states can still set their own enrollment deadlines, provided it is not earlier than December 15 for those that operate their own exchanges. New Mexico, Maine, and Kentucky will join the 15 existing exchanges that are entirely state-run for 2022 coverage. There will be 18 fully-state-run exchanges with the ability to offer open enrollment.

The state-run exchanges have announced the following deadlines. (Note that you can still make changes during the open enrollment, and some exchanges may extend their deadlines last-minute).

California – January 31st
Colorado – January 15
Connecticut – January 15
District of Columbia – January 31
Idaho – December 15; no extension!
Kentucky -January 15
Maine – January 15
Maryland – January 15
Massachusetts – January 23
Minnesota – January 15
Nevada – January 15
New Jersey – January 31
New Mexico – January 15
New York – January 31
Pennsylvania – January 15
Rhode Island – January 31
Vermont – January 15
Washington – January 15

Where Is ACA Enrollment Still Available For 2021 Coverage?

The special enrollment period for COVID/American Rescue Plan was opened by the Biden administration on HealthCare.gov shortly after the close of the open enrollment period. The SEP was open to anyone who could use the Affordable Care Act’s Marketplace, even those who had coverage through HealthCare.gov but wanted to switch to a different plan. This window does not require a qualifying event.

HealthCare.gov is used in 36 states to enroll in 2021 health plans. The special enrollment period was open in all 36 states, but it ended in those states on Aug 15, 2021. However, HealthCare.gov still allows people to sign up for coverage even after the date. This is if they are eligible for ARP’s subsidies for people who received unemployment compensation in 2021.

Moreover, all state-run exchanges offered COVID-related special enrollment times in 2021. Some ended earlier than others, while others ran longer than the window on HealthCare.gov.

Numerous state-run exchanges (Colorado and Maryland, Nevada, Pennsylvania. Rhode Island, and Washington) closed their COVID-related special enrollment period on August 15. This was in line with HealthCare.gov’s schedule. Some had also ended theirs in 2021 (Idaho and Massachusetts).

The following states are still able to enroll in 2021 coverage, even without any qualifying events:

  • California through December 31
  • DC: Through the expiration of the pandemic emergency phase
  • Minnesota: The COVID-related general enrollment period has expired. However, people who received unemployment compensation in 2021 may still enroll or change plans to a $0 premium Silver plan.
  • New Jersey through December 31
  • New York through December 31

Who Is Eligible To Enroll In ACA-Compliant Healthcare Plans All Year?

All eligible residents can enroll in Medicaid or CHIP year-round.  You can also enroll year-round in the Basic Health Programs of Minnesota and New York.

Eligible residents can also enroll in the new Covered Connecticut program until the end of December 2021. For those new to the ConnectorCare program or who have not enrolled previously, enrollment is open all year for this program in Massachusetts.

Native Americans and Alaska Natives are eligible to enroll in exchange plans year-round. In addition, eligible applicants for Medicaid and CHIP may also enroll year-round. This applies to all years, not just 2021.

CMS has now finalized a rule that allows individuals with incomes up to 150% below the poverty line to enroll year-round as long as the American Rescue Plan’s subsidy enhances is in place. This rule is in effect until the end of 2022, but Congress is expected to extend it.

Dc, Colorado, And California Have Permanently Extended ACA Open Registration

As mentioned above, most fully state-run exchanges have stretched 2022 open coverage enrollment until January 15, 2022. Some, such as New York, have extended open enrollment to the end of January, while others, like New York City, do not. Three have implemented legislation or regulations to codify extended open enrollment periods:

  • California: December 1 – January 31. California passed legislation in 2017 that established new enrollment dates for the state. This law applies to both off-exchange and on-exchange. Open enrollment for 2022 healthcare plans will start November 1, 2021, and continue until January 31, 2022. California’s enrollment calendar has been inconsistent in the past, but the three-month window that runs from the beginning of November to the end of January will continue to be the permanent enrollment window.
  • Colorado: November 1 – January 15. Open enrollment has been extended by Colorado’s Division of Insurance. In late 2018, the state-approved regulations provide an annual special enrollment period from December 16 through January 15. This is added to each year’s close of open enrollment. Open enrollment in Colorado will last 2.5 months during all future enrollment periods (November 1, January 15, and after that). The plans selected between December 16th and January 15 should take effect by February 1.
  • DC: November 1 – January 31.  DC’s exchange board unanimously approved the permanent implementation of an open enrollment window, which runs from November 1 to January 31,

State-Run Marketplaces Offer Some Flexibility In The Open Enrollment Schedule

According to the 2017 market stabilization rule, the open enrollment period from November 1-December 15 would be available in all states in the fall of 2017. They also pointed out that state-based exchanges, which number 15 as of 2021 and 18 by 2022, respectively, might have had logistical problems getting their systems ready for the new schedule.

Accordingly, the market stabilization rules clarified that state-based markets could use their flexibility to “supplement open enrollment with a special enrollment phase, as a transitional measure to account for those operational problems.”

Obamacare Open Enrollment Is Not Extended To January 15th In All 50 States

HHS previously defined open enrollment to be the period between November 1 and December 15. However, state-run exchanges had the option of offering special enrollment periods before or after that window to extend open enrollment.

HHS has modified the enrollment window for HealthCare.gov to allow coverage in 2022 and beyond. It is now from November 1 to January 15. Instead of mandating state-run exchanges use an enrollment window of at least two months, HHS gives them the option to keep a shorter deadline as long as it is not before December 15. Some state-run exchanges can choose a mid-December deadline. However, most will extend their enrollment windows until January 15.

Only Vermont and Maryland retained the December 15 deadline for enrollments in 2021. However, both states joined the rest to reopen enrollment for 2021 coverage to address the ongoing COVID pandemic and the American Rescue Plan’s new subsidies.

New Mexico, Maine, Kentucky, and others will have their own enrollment platforms in the fall of 2021, as noted above. Only entirely state-run exchanges have the power to extend open enrollment. In the rest of the states, CMS has to make the decision. Most exchanges have made a choice to do this each year. HHS has extended January 15 as the deadline for HealthCare.gov, and many state-run exchanges will likely use this data to extend enrollment. Most of them close their enrollment windows around mid-January every year.

The Special Enrollment Period Is Only Available With A Qualifying Event Outside Of ACA’s Open Enrollment Window

People can only buy coverage after open enrollment closes, usually because they have a particular enrollment period that was triggered by a qualifying event, such as:

  • The marriage coverage is only valid if at least one spouse had coverage prior to the wedding. However, there are exceptions.
  • Becoming a U.S. citizen
  • Adoption or birth
  • Involuntary termination of any other health coverage
  • A permanent move to an area with new health plans (since July 2016, this is only applicable if you had coverage before your move).
  • This guide will provide you with all the information needed to qualify for events in the individual market and any special enrollment periods.

Whether you buy insurance via the exchange or off or using a local insurance agent, the annual open enrollment window is applicable. Special enrollment periods are required to enroll at other times of the year.

COVID/American Rescue Plan special enrollment times in 2021 are exceptions to the usual rules. Qualifying events are not required in order to be eligible for these enrollment windows.

Ten Things To Look Out For In Open Enrollment 2022

Even though the ninth yearly Open Enrollment period is about to begin, the Affordable Care Act Marketplaces are still evolving, and significant changes can be expected. Keep an eye out:

1. Open Enrollment Dates Are Developing

The Open Enrollment period in most states will be extended this year. It has been a 6-week period in HealthCare.gov states. But it will now run from November 1, 2021, to January 15, 2022. If you want coverage to begin on January 1, people must sign up before December 15. If you sign up later, coverage will start on February 1. The state-run marketplaces can hold longer OE periods, and some will.

2. Plan Choices And Premiums Will Change In 2022

In 2022, the premiums for market plans will be subject to some variation, as it does every year. The average benchmark plan premium in HealthCare.gov states will be around 3% lower than in 2021. However, qualified health plan premiums may increase slightly on average in some state-based marketplaces.

The number of marketplace insurers will also increase in 2022. Thirty-two more insurers in HealthCare.gov’s states will provide marketplace coverage, bringing it to 213. In addition, insurers can sometimes alter the benchmark plan (the second-lowest-cost silver plan on which market subsidies are based) if a new plan is approved in 2022. In 2022, HealthCare.gov states consumers will have access to nearly 83 quality health plans instead of 46 plans 2021.

3. Market Subsidies Are Improving And Will Continue To Reduce Net Premiums For Most Customers

The American Rescue Plan Act (ARPA) enacted expanded marketplace premium subsidies in 2021 and will remain in force for 2022. Premium tax credits have increased in dollar value and fully cover the cost for consumers earning up to 150% FPL to enroll in the benchmark silver plan. Consumers with 150% FPL were required to pay more than 4% of their household income before enrolling in the benchmark plan. In addition, cost-sharing subsidies are available for people with 150% FPL. They significantly reduce deductibles, copays, and other costs under zero-premium Silver plans. These plans are similar to platinum plans.

ARPA also expanded eligibility for premium tax credits for people who earn over 400% FPL ($51520 for a single person, $87840 for a family of three). These consumers must contribute no more than 8.5% of their income towards the benchmark silver plan. The premium paid for benchmark plans by an age-rated consumer could easily exceed 20% of household income for older consumers. The ARPA premium tax credit change is temporary and will end after 2022. However, legislation to make them permanent in Congress is currently pending.

The KFF Subsidy Calculator helps you estimate how much financial assistance you will receive based on your age, income, and zip code.

4. Active Renewing Is Strongly Recommended

If enrollees do not update their plan selection or application for 2022, the marketplace can auto-re-enroll them into their existing plan or another similar plan in the next year. About 40% of the marketplace participants who returned in the past three Open Enrollment periods were auto-reenrolled.

Passively renewing is a disadvantage for consumers. If the benchmark plan is changed from year to year (e.g., due to new insurers), the dollar value tax credits can change. These credits are linked to the cost of the benchmark plan. Passively renewing an enrolled member of the 2021 benchmark plan could result in unexpected premium increases if a new plan is introduced in 2022 that costs less.

If they do not renew, enrollees who didn’t take advantage of the new ARPA subsidies this year may also be affected. Although the market automatically adjusted subsidies for most current enrollees at this year’s COVID-SEP, they could not provide more assistance to those already in zero-premium Bronze plans. Nearly 800,000. HealthCare.gov enrollments were in zero-premium bronze plans at the close of Open Enrollment 2021.

Many of these enrollees would benefit from silver plans with new ARPA subsidies. Regardless of personal circumstances, market enrollees are encouraged to update their applications during Open Enrollment. This will allow them to see all the current financial assistance and plan details. If consumers do not update their application during Open Enrollment, there will be a brief window of opportunity (until January 15) when they can make any changes.

5. People With Very Low Income Will Have Added Time To Enroll

HealthCare.gov will offer enrollment for individuals with incomes up to 150% below the federal poverty line (or FPL) starting in 2022. This is $19,320 per person per year or $32,940 per family of 3. Each month will offer a new enrollment opportunity. Plan options will include zero-premium plans and significantly reduced deductibles. Sign up for the year by proving that you have a 2022 income below 150% FPL. Then, continue your application. Marketplace will verify income in real-time, just like it does for all applicants. It may ask for additional documentation within 90 days. HealthCare.gov may ask for documentation if consumers believe their 2022 income is substantially lower than that reported on their federal income tax returns.

Extended enrollment could benefit millions of people. Nearly 1/3 of participants in the marketplace had incomes below the 150% FPL threshold at the end of the previous Open Enrollment. During the COVID enrollment opportunity in 2021 for HealthCare.gov, 45% of those signing up in HealthCare.gov (22%) in state marketplaces had incomes below this threshold. While Open Enrollment is still the best way to sign up for year-long coverage for a year, the increased enrollment opportunities will make signing up for premium-free plans and low-cost-sharing for the entire year easier.

6. More Enrollment Help Will Be Available

After years of significant funding cuts, averaging 84%, the funding for Navigators in HealthCare.gov states has been restored. The marketplace has certified Navigators, who offer free assistance to those looking for coverage in the market or subsidies. They also help people sign up for Medicaid and CHIP. In 2022, there will be twice as many programs, plus more resources available to consumers. This includes extended hours and remote assistance. You can find contact information, hours of operation, and contact information for local programs by clicking the “Find Local Help” link on HealthCare.gov.

7. Three New State-run Markets Will Open

Three states, Maine and New Mexico will launch state-based marketplaces this fall. These states have 173,000 residents who are already enrolled in HealthCare.gov plans. They will be able to transfer their data to the new state marketplace and receive instructions on how to access their accounts and enroll in 2022 coverage.

8. New Surprise Medical Bills Protection Will Take Effect

Many marketplace plans are EPOs or HMOs with closed provider networks. This means that they do not typically cover non-emergency care from out-of-network providers. And even when plans cover out-of-network claims, consumers could be charged “balance billing,” which is an additional charge to their plan. However, a new federal law will protect consumers from unexpected medical bills. All insurance plans, marketplace or not, must now cover emergency services (other than ground ambulance) at their in-network rates. In addition, out-of-network emergency rooms facilities and doctors cannot bill patients for more than the in-network cost-sharing amount. These protections also apply to non-emergency services received at hospitals or ambulatory surgery centers part of the in-network network.

9. Some Recent Changes Have Changed Back

It will be crucial for consumers to accurately estimate their 2022 income this year when applying for market subsidies. People who filed their 2020 tax returns this spring were exempted from repaying the 2020 premium tax credit. However, the repayment requirement is back in effect. If they claim excess premium credit credits, consumers who underestimate their 2022 income could be subject to higher taxes. To avoid being denied subsidies, people should immediately update their marketplace account if they notice a substantial change in their 2022 income.

Trump Administration revisions to “public charge,” which would have made it more difficult for immigrants to stay or enter the U.S. if they required public assistance to get health coverage, were reversed this year. This action discouraged many people from applying or staying enrolled in health insurance, fearing that it could affect their immigration status. The Trump Administration’s changes to the public charge rule were canceled by the Biden Administration this year. Under current rules, immigration officials won’t consider enrolling in Marketplace, CHIP, or Medicaid coverage when people apply to get a green card.

10. Will New Enrollment Records Be Set?

As most states’ special COVID enrollment period ended in August 2021, marketplace enrollment hit a record high at 12.2 million. This result is likely due to affordability gains, outreach and enrollment assistance, and expanded subsidies. KFF’s October 2021 poll showed that just 1 in 4 Americans who have no insurance or buy their own healthcare insurance check to see if they are eligible for additional assistance after the ARPA subsidy enhancements became available.

KFF estimates that nearly 11 million Americans are eligible for but not enrolled in subsidized market plans. This includes 1.4 million who were newly eligible for marketplace subsidies. These uninsured people, even those eligible for zero-premium plans and have a high percentage of Hispanic origin, are young adults from rural areas or do not have access to the Internet at home. The next Open Enrollment will reveal whether more people sign up with additional enrollment assistance and financial support.

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