Q. What is the deadline to enroll in health insurance coverage in the individual market?

A.  In most states, open enrollment for 2021 health plans ended on December 15, 2020. HealthCare.gov, which is the exchange platform that’s used by the majority of the states, tends to follow this schedule fairly closely, while the states that run their own exchange platforms generally offer slightly longer enrollment windows.

HealthCare.gov is being used in 36 states for enrollment in 2021 health plans (it was 38 states as of 2020, but Pennsylvania and New Jersey have both transitioned to their own enrollment platforms as of the fall of 2020; both have also opted to extend their open enrollment windows).

As described below, California, Colorado, and DC have opted to permanently extend their open enrollment periods. And most of the other fully state-run exchanges have opted to extend the open enrollment period for 2021 coverage, meaning it will continue past December 15.

Outside of open enrollment, plan changes and new enrollments are only possible for people who experience a qualifying event.

Native Americans and Alaska Natives can enroll year-round in plans offered in the exchange. Applicants who are eligible for Medicaid or CHIP can also enroll year-round.

States where open enrollment ended on December 15, 2020

In the following states, open enrollment ended on December 15 (although due to high call volume on December 15, HealthCare.gov had some callers leave their contact information; the exchange will call these people back over the next few days to complete their enrollment in 2021 coverage):

• Alabama
• Alaska
• Arizona
• Arkansas
• Delaware
• Florida
• Georgia
• Hawaii
• Illinois
• Indiana
• Iowa
• Kansas
• Kentucky
• Louisiana
• Maine
• Maryland (but Maryland has opened a COVID-related special enrollment period through March 15, 2021)
• Michigan
• Mississippi
• Missouri
• Montana
• Nebraska
• New Hampshire
• New Mexico
• North Carolina
• North Dakota
• Ohio
• Oklahoma
• Oregon
• South Carolina
• South Dakota
• Tennessee
• Texas
• Utah
• Vermont (state had the option to extend enrollment but chose not to do so)
• Virginia
• West Virginia
• Wisconsin
• Wyoming

California, Colorado, and DC: Open enrollment has been permanently extended

California: November 1 – January 31. California enacted legislation in 2017 and again in 2019 that permanently establishes different enrollment dates within the state, both on and off-exchange. Open enrollment for 2021 health plans began November 1, 2020 and will continue through January 31, 2020. California’s enrollment schedule has varied in previous years, but this three-month window, from the beginning of November through the end of January, will be the permanent enrollment window going forward.

Colorado: November 1 – January 15. Colorado’s Division of Insurance has also permanently extended open enrollment. The state finalized regulations in late 2018 that call for an annual special enrollment period, running from December 16 to January 15, that is added to the end of open enrollment each year. So open enrollment in Colorado will effectively last 2.5 months for all future enrollment periods (November 1 to January 15). Plans selected between December 16 and January 15 must take effect no later than February 1 (for 2021 coverage, the exchange is giving people until December 18 to enroll, although they have to call the customer service center to request a January 1 effective date if they’re enrolling between December 16 and 18).

DC: November 1 – January 31. DC’s exchange board voted unanimously to permanently implement an open enrollment window that runs from November 1 to January 31.

Enrollment for 2021 health plans still open in ten states and DC

In addition to the three permanent extensions described above, open enrollment for 2021 health plans has also been extended in ten of the other 12 fully state-run exchanges. The extended deadline has already passed in Minnesota and Idaho, but open enrollment is still ongoing as of early January in ten states and DC, with the following enrollment deadlines:

• Colorado: January 15
• Connecticut January 15
• Pennsylvania: January 15
• Nevada: January 15
• Washington: January 15
• Massachusetts: January 23
• Rhode Island: January 23
• California: January 31
• DC: January 31
• New Jersey: January 31
• New York: January 31

The deadline for a January 1 effective date has passed in all of those states, so enrollments are currently (as of early January) being processed for a February 1 effective date.

Although open enrollment ended on December 15 in Maryland, the state announced in early January that it was opening a new COVID-related special enrollment period that will continue through March 15, 2021. Uninsured Maryland residents can use this window as an opportunity to enroll in coverage through Maryland’s exchange, but people who already have coverage cannot make plan changes during this window.

Minnesota‘s exchange and Idaho‘s exchange also extended open enrollment, but they ended December 22 and December 31, respectively. Idaho announced its extension on December 18 (three days after the original deadline had passed; this is the first time Idaho’s exchange has ever added a significant extension to open enrollment). Connecticut stuck with a December 15 deadline right up until the end of open enrollment, and then announced an additional month starting on December 16.

The only other fully state-run exchanges are in Vermont and Maryland, so they’re the only other states that had the option to extend open enrollment beyond the deadline that HealthCare.gov imposes. But both of them opted to end open enrollment on December 15. As noted above, however, Maryland is allowing uninsured residents a COVID-related special enrollment period that continues through March 15, 2021.

State-run exchanges have some flexibility on open enrollment schedule

The 2017 market stabilization rule noted that the November 1-December 15 open enrollment period would apply in every state in the fall of 2017. However, they also noted that some state-based exchanges — there are 13 of them as of 2020, and potentially 16 as of 2021 — might experience logistical difficulties in getting their systems ready for the new schedule on a fairly tight timeframe.

As such, the market stabilization rule clarified that state-based exchanges could use their own flexibility to “supplement the open enrollment period with a special enrollment period, as a transitional measure, to account for those operational difficulties.” Since then, the majority of the state-based exchanges have opted to extend open enrollment for most years.

For 2020 enrollments, Maryland, Vermont, and Nevada opted to keep the December 15 end date (and Idaho came very close to it; their reason for a one-day extension was that their call center isn’t open on Sundays, and the 15th fell on a Sunday. In general, Idaho residents should expect that the enrollment window will not be extended in the future, given how well they’ve adhered to that deadline for the last few years).

As we can see from the decisions in DC, California, and Colorado (to permanently extend open enrollment), and in Pennsylvania and Nevada (to extend open enrollment for 2021 coverage), states with their own enrollment platforms still have flexibility going forward. HHS has defined open enrollment as the window from November 1 to December 15, and that applies in every state. But state-run exchanges have the option to offer special enrollment periods before or after that window, in order to effectively extend open enrollment.

In addition to Pennsylvania, New Jersey is expected to also have state-run exchange platform by the fall of 2020; New Mexico plans to join them in the fall of 2021, and Maine might do so as well by the fall of 2021. Oregon may join them in the future as well. Fully state-run exchanges are the only ones with the ability to extend open enrollment on their own (in the other states, the decision has to come from CMS, since the extension has to be issued via HealthCare.gov), and most of them have been choosing to do so each year.

Outside of the open enrollment window, enrollment is only available with a qualifying event

After open enrollment ends, people can only purchase coverage if they have a special enrollment period triggered by a qualifying event such as:

• Marriage (since 2017, this generally only applies if at least one spouse already had coverage before the wedding, although there are some exceptions),
• Becoming a U.S. citizen,
• Birth or adoption,
• Involuntary loss of other health coverage.
• A permanent move to an area where new health plans are available (since July 2016, this only applies in most cases if you already had coverage prior to your move).
• Here’s a complete guide to qualifying events in the individual market, and their associated special enrollment periods.

Regardless of whether you purchase insurance through the exchange or off-exchange, the annual open enrollment window applies, and special enrollment periods are necessary in order to enroll at any other time of the year.

In 2016, HHS tightened up the rules regarding eligibility for special enrollment periods, and they further tightened the rules in 2017, as part of the market stabilization rule. As a result, the rules are being followed much more closely than they were in previous years, and in most states, anyone enrolling during a special enrollment period is required to provide proof of the qualifying event that they experienced.

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Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

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