Now that we’ve passed the March 31, 2014 open enrollment deadline for signing up for individual health insurance coverage, many employers (and their brokers) are asking if it's too late for employees to get coverage on the exchanges.
Is it Too Late for Employees to Get Individual Coverage on the Exchanges?
No. In many situations, it's not too late.
We're hearing this question mostly from employers with mid-year renewals (ex: in June or July) who are thinking about canceling group health insurance or limiting eligibility for some or all of their employees. They want to make sure that employees losing group coverage will be able to get individual coverage before the next open enrollment period this fall.
In the situation described above, all employees who lose access to their group health insurance coverage are automatically eligible for a special enrollment period to sign up for individual coverage on the exchange or through a broker.
For example, the annual open enrollment period for individual coverage ended March 31, 2014. "ABC Veterinarian Clinic" decided to cancel group health coverage as of May 31, 2014. Because of this, all employees (and dependents) covered under the group health insurance plan are now eligible for a special enrollment period to enroll in individual coverage. In this example, employees would have from June 1st until July 30th (60 days) to enroll in individual coverage.
Other Ways Employees Can Get Coverage Outside of Open Enrollment
In addition to canceling group health insurance coverage, there are various extensions and qualifying life events that make employees eligible for a special enrollment period. Examples include:
Change in Family Size: You get married or divorced, have a death in the family, or have a child by birth or adoption.
Change Citizenship Status: You become a U.S. citizen, national, or gain lawful status in the U.S.
Experience Government Error: You lose, change, or enroll in coverage because of an error committed by an officer, employee or agent of the Exchange or the Department of Health and Human Services as determined by the Exchange.
Change Premium Tax Credit Eligibility: You are determined newly eligible or newly ineligible for federal assistance (advance payments of the premium tax credit, cost sharing reductions, or Medicaid). See eligibility for premium tax credits here.
Move to a New Coverage Area: You permanently move to a new area (ex: state or county) and gain access to new qualified health plans.
- You started an online application prior to March 31st, but did not finish it.
In many ways, special enrollment periods and qualifying events in the individual health insurance market look a lot like the special enrollment periods with employer-sponsored group health insurance plans.
This means that when determining whether or not to continue a plan in its current form, to cancel coverage, or to change eligibility, you should not assume that it's too late for employees to get new coverage on the exchanges.