Marketplace Plan Discontinued? Options after Open Enrollment

Blink and you may have missed it. Open enrollment for HealthCare.gov was much shorter this year and ended on December 15, 2017.* Individuals with discontinued health plans, however, may still be able to enroll in a marketplace or off-marketplace plan through a special enrollment period. Not having coverage because of a discontinued health plan is a loss of minimum essential coverage, which triggers a special enrollment period. Individuals in Arizona, Georgia, Illinois, Nebraska, Ohio, Virginia and many other states where insurers have withdrawn from the marketplace or discontinued plans may be able to use this special enrollment period to purchase coverage for 2018. We’ve rounded up some frequently asked questions about discontinued plans and special enrollment period.

My marketplace health plan is being discontinued and I didn’t go back to the marketplace to select a new plan during open enrollment. But open enrollment is over. What are my options?

In this situation, you qualify for a special enrollment period since you are losing minimum essential coverage. Under the loss of minimum essential coverage special enrollment period, you have 60 days before and after the last day of coverage to choose another marketplace plan. So if your 2017 coverage ends on December 31, 2017, you can contact the marketplace now to get a special enrollment period. When 2018 coverage becomes effective depends on when you select a plan.

  • If you select a plan on or before December 31, 2017, your 2018 coverage effective date is January 1, 2018;
  • If you select a plan on or before January 31, 2017, your 2018 coverage effective date is February 1, 2018;
  • If you select a plan on or before February 28, 2018, your 2018 coverage effective date is March 1, 2018.

This special enrollment period is also available to you for off-marketplace coverage. Note that the marketplace will require that you provide verifying documents of your loss of minimum essential coverage before you can enroll. You will have 30 days to submit the documentation. Also, under marketplace rules for 2018, you will be limited in your plan selection. See this FAQ in our Navigator Guide for more information. (45 C.F.R. § 155.420(d); 82 Fed. Reg. 18346, April 18, 2017; CMS, Overview: Special Enrollment Period Pre-enrollment Verification (SEPV), June 2017).

My marketplace health plan is being discontinued and I got re-enrolled into a different plan. I don’t like this new plan, but open enrollment is over. What are my options?

As long as you have not paid your first month’s premium for the new plan, thereby effectuating coverage, you qualify for a special enrollment period to enroll in a different plan. Since your 2017 health plan is being discontinued, you are losing minimum essential coverage, a qualifying event that triggers a special enrollment period. Under the special enrollment period, you have 60 days before and after the last day of coverage to choose another marketplace plan. Since your 2017 coverage ended on December 31, 2017, you can contact the marketplace now to get a special enrollment period. When 2018 coverage becomes effective depends on when you select a plan.

  • If you select a plan on or before December 31, 2017, your 2018 coverage effective date is January 1, 2018;
  • If you select a plan on or before January 31, 2017, your 2018 coverage effective date is February 1, 2018;
  • If you select a plan on or before February 28, 2018, your 2018 coverage effective date is March 1, 2018.

This special enrollment period is also available to you for off-marketplace coverage. Note that the marketplace will require that you provide verifying documents of your loss of minimum essential coverage before you can enroll. You will have 30 days to submit the documentation. Also, under marketplace rules for 2018, you will be limited in your plan selection. See this FAQ in our Navigator Guide for more information. (45 C.F.R. § 155.420(d); 82 Fed. Reg. 18346, April 18, 2017; CMS, Overview: Special Enrollment Period Pre-enrollment Verification (SEPV), June 2017).

*While open enrollment via HealthCare.gov ended on December 15th, several state-based marketplaces extended the window for people to enroll in marketplace coverage. A full list of states and their open enrollment deadlines is available here.

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