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New Exchange Special Enrollment Periods and Hardship Exemptions

Under the Affordable Care Act (ACA), individuals may only enroll in health insurance through an Exchange during a permitted enrollment period (such as an open enrollment or a special enrollment period). The initial open enrollment period for Exchange coverage ended on March 31, 2014. The open enrollment period for 2015 will begin on Nov. 15, 2014, and extend through Feb. 15, 2015.

On May 2, 2014, the Department of Health and Human Services (HHS) issued a Bulletin providing special enrollment periods (SEPs) in the federally-facilitated Exchange (FFE) for the following individuals:

  • Individuals who are enrolled in (or eligible for) COBRA coverage
  • Individuals whose individual market plans renew outside of the Exchange’s open enrollment period
  • AmeriCorps/VISTA/National Civilian Community Corps (NCCC) members

If certain conditions are met, the SEPs allow these individuals to enroll in qualified health plans (QHPs) outside of an open enrollment period. HHS encourages state-based Exchanges (SBEs) to adopt similar special enrollment periods for these individuals. In addition, the HHS Bulletin provides a hardship exemption from the individual mandate’s penalties. This exemption is for all months prior to the effective date of coverage for all individuals who obtained minimum essential coverage (MEC) effective on or before May 1, 2014, even for individuals who purchased coverage outside of the Exchange. It is available for eligible consumers in FFE and SBE states.

Special Enrollment Periods Overview

Individuals may be allowed an SEP in an Exchange following certain triggering events, such as marriage or birth of a child. SEPs permit individuals to enroll in QHPs outside of open enrollment. In addition, an SEP will be provided in cases where a consumer faces exceptional circumstances, as determined by HHS, that occur on or around plan selection deadlines.
The effective date of any coverage elected during an SEP follows rules similar to those applicable during open enrollment. This means that coverage would generally be effective as of the first day of the month for elections made by the 15th of the preceding month, and on the first day of the second following month for elections made between the 16th and the last day of a given month. However, special rules apply when birth, adoption or placement of a child is the special enrollment triggering event. In general, SEPs triggered by exceptional circumstances will have prospective coverage effective dates.

To read more about the New Exchange Special Enrollment Periods and Hardship Exemptions, click here.

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