Small Business Employee Benefits and HR Blog

What dates to know - open enrollment 2020

Deadlines for enrolling in Marketplace coverage.

October 18, 2019
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It’s that time of year again. Open enrollment for most states is starting soon and in some states it’s already begun. You may be wondering why open enrollment matters and which deadlines apply to you.

Open enrollment is important because it’s the only time consumers can sign up for individual health insurance without experiencing a qualifying life event.  A qualifying event triggers a special enrollment period (SEP) that allows individuals and their dependents to enroll in coverage up to 60 days before or after the date of the event. Those who miss open enrollment deadlines and aren’t eligible for an SEP must wait until the following year’s open enrollment to sign up for coverage.  

In this post, we'll discuss each state's open enrollment periods as well as other information relating to QSEHRAs, ICHRAs, and alternate enrollment options.

Open enrollment dates for HealthCare.gov 

Residents in states that use the federal exchange, HealthCare.gov, will have from November 1 to December 15 to select and purchase a policy.

States using HealthCare.gov include:

  • Alabama
  • Alaska
  • Arizona
  • Arkansas
  • Delaware
  • Florida
  • Georgia
  • Hawaii
  • Illinois
  • Indiana
  • Iowa
  • Kansas
  • Kentucky
  • Louisiana
  • Maine
  • Michigan
  • Mississippi
  • Missouri
  • Montana
  • Nebraska
  • Nevada
  • New Hampshire
  • New Jersey
  • New Mexico
  • North Carolina
  • North Dakota
  • Ohio
  • Oklahoma
  • Oregon
  • Pennsylvania
  • South Carolina
  • South Dakota
  • Tennessee
  • Texas
  • Utah
  • Virginia
  • West Virginia
  • Wisconsin
  • Wyoming

If residents in these states enroll in a plan by December 15, coverage will begin on January 1 and they’ll qualify as insured in 2020.

Open enrollment dates for state exchanges

Some states have chosen to run their own health insurance exchange. Many of them decided to extend open enrollment by at least a week, however, some are using the official federal timeline.

These states—and their enrollment dates—are:

  • California: October 15, 2019, to January 15, 2020
  • Colorado: November 1, 2019, to January 15, 2020
  • Connecticut: November 1, 2019, to December 15, 2019
  • Idaho: November 1, 2019, to December 15, 2019
  • Maryland: November 1, 2019, to December 15, 2019
  • Massachusetts: November 1, 2019, to January 23, 2020
  • Minnesota: November 1, 2019, to December 23, 2019
  • New York: November 1, 2019, to January 31, 2020
  • Rhode Island: November 1, 2019, to December 31, 2019
  • Vermont: November 1, 2019, to December 15, 2019
  • Washington: November 1, 2019, to December 15, 2019
  • Washington, DC: November 1, 2019, to January 31, 2020

If you’re a resident in one of the states not using the standard federal open enrollment period, you can expect your coverage to begin on a different date depending on when you purchased your policy.

Here's a table with that information.

State

January 1 effective date deadline

February 1 effective date deadline

March 1 effective date deadline

California

December 15, 2019

January 15, 2020

Colorado

December 15, 2019

January 15, 2020

Connecticut

December 15, 2019

Idaho

December 15, 2019

Maryland

December 15, 2019

Massachusetts

December 23, 2019

January 23, 2020

Minnesota

December 15, 2019

January 13, 2020

New York

December 15, 2019

January 15, 2020

January 31, 2020

Rhode Island

December 31, 2019

Vermont

December 15, 2019

Washington

December 15, 2019

Washington, DC

December 15, 2019

January 15, 2020

January 31, 2020

Open enrollment and QSEHRAs

Employees that are offered a qualified small employer HRA (QSEHRA) in 2020 must have minimum essential coverage (MEC) in place to receive tax-free reimbursements. Open enrollment is usually the best time to secure an MEC policy, though beginning in 2020, employees who become newly eligible for a QSEHRA will have access to a 60-day special enrollment period (SEP).

If employees have a policy through a parent’s plan or a spouse’s employer-sponsored plan that qualifies as MEC, they don’t need to purchase an individual policy to get tax-free reimbursements.

After purchasing a policy, individuals can submit documentation verifying their premiums to their company. Once their employer has verified the expense, they will reimburse the employee for their monthly premiums, as well as all other qualified expenses that were submitted.

Individuals that don’t have MEC can still participate in a QSEHRA, but they’ll need to report reimbursements as taxable income.

Open enrollment and ICHRAs

Employees and their families that are offered an individual coverage HRA (ICHRA) are only eligible to participate if they have coverage under an individual health insurance policy. That means that, unlike a QSEHRA, employees who are covered on a parent’s or spouse’s plan are not eligible to participate in an ICHRA. If the employee or a participating family member doesn’t obtain (or loses) individual coverage, they can’t receive reimbursements through the plan. 

As with the QSEHRA, being newly eligible for an ICHRA does trigger a 60-day SEP from the first date of the plan. It’s important to keep in mind that for a January 1 start date, open enrollment is still likely the best time to enroll in coverage. 

What if I miss open enrollment?

Those who miss 2020 open enrollment and don’t qualify for an SEP will need to wait until 2021 open enrollment to purchase an individual health insurance policy with MEC.

It's vital that anyone who wants to have coverage under an individual policy with MEC in 2020 be aware of these deadlines and whether they’ll have a life event that triggers an SEP. 

 

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