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How States Are Increasing Coverage through Special Enrollment Periods

Updated September 28, 2020

Absent a pandemic, enrollees usually sign up for insurance coverage during the annual open enrollment period, from Nov. 1- Dec. 15. However, under extenuating circumstances, consumers can sign up during a special enrollment period (SEP). The Affordable Care Act defined a set of events that trigger SEPs nationally (view a national list of SEPs), but state-based marketplaces have limited discretion over when to schedule additional SEPs for their consumers. Many have enacted SEPs in response to the COVID-19 pandemic to give uninsured residents an opportunity for coverage, which reduces financial barriers in the event they need medical care. Below is a list of the unique SEPs available in state-based marketplaces, including life-changing events, unexpected health plan changes, or enrollment in dental coverage.

What Events Qualify for a Special Enrollment Period in State-Based Marketplaces
Qualifying Event CA CO CT DC ID MD MA MN NV NY RI VT WA
Special Enrollment Periods (SEPs) triggered by unique life events:
Loss of coverage upon leaving military service x
Loss of “hardship exemption” (exemption from individual mandate penalty) x x x x
A change in disability status x               x        
Pregnancy (self-attested or requiring verification)     x x   x       x   x  
Newly eligible for state coverage because of change in income             x            
Beginning or end of state hardship waiver that reduces or waives premiums             x            
SEPs triggered due to insurance market changes:
Health insurance plan became decertified during the coverage year x   x                    
Provider left health plan network while enrollee was receiving care or treatment for illness x                        
SEPs due to eligibility/ reconciliation issues:
Was conditionally approved for Medicaid during open enrollment period (OEP) or SEP, but was ultimately denied and received denial notice after the OEP/SEP ended x     x       x         x
Enrollee was automatically renewed into a different plan without forewarning because original plan was no longer offered x
Consumer’s employer was going to enroll employees in SHOP coverage, but was denied because too few employees selected coverage x
Tax filer learned of state/district individual mandate during tax season or was assessed a tax penalty through the mandate x x x
SEPs due to technical issues or extenuating circumstances:
SEP triggered for victims of a natural disaster (ex., wildfires). x                        
Loss of coverage due to the failure of a provider/provider-funded third party to pay enrollee’s premium on a timely basis (effective 7/1/2020) x                        
Termination of coverage caused by a problem with automatic payment (e.g., because credit card was discontinued because of fraudulent activity) x     x                  
Acts of foreign or domestic terror prevented enrollee from meeting enrollment deadlines x                       x
SEP triggered in the event of a public health emergency* x x x x   x x x x x x x x
Customer’s enrollment issue (non-system error) was not resolved before the end of OEP x   x         x         x
SEPs triggered by fraudulent coverage:
Purchased fraudulent coverage policy through Simple Health insurance company (temporary; expired) x x x x x x x
Bought other fraudulent coverage (e.g., coverage that misrepresented itself as comprehensive coverage) x
Member of Aliera “health-sharing ministry” and wished to switch to comprehensive plan (temporary; expired) x x
SEPs for enrollment in dental plan:
Consumer is newly eligible for Medicaid or qualified health plan, enrolled in SHOP, or gained access to an excepted benefits health reimbursement arrangement and otherwise lacks dental coverage           x              
Open SEP to purchase dental coverage             x            
Loss of other dental coverage                     x    

Updated September 28, 2020

*Time-limited SEPs created in response to the COVID-19 national emergency. These SEPs are/were open during the following periods.

CA 3/20/20 – 8/31/20
CO 3/20/20 – 4/30/20
CT 3/19/20 – 4/17/20
DC 3/18/20 – 9/15/20
MD 3/16/20 – 7/15/20; 8/7/20-12/15/20
MA 3/11/20 – 5/25/20
MN 3/23/20 – 4/21/20
NV 3/17/20 – 5/15/20
NY 3/16/20 – 9/15/20
RI 3/14/20 – 4/30/20
VT 3/20/20 – 6/15/20
WA 3/09/20 – 5/08/20

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