via the Colorado Dept. of Regulatory Agencies Insurance Division, it looks like Connect for Health Colorado is about to go ahead and establish their own COVID-19 Special Enrollment Period after all (this is from an internal draft document...the dates could still change, and it's not 100% guaranteed that they'll go ahead with it yet):
DEPARTMENT OF REGULATORY AGENCIES Division of Insurance 3 CCR 702-4 LIFE, ACCIDENT AND HEALTH
DRAFT Emergency Regulation 20-E-02
CONCERNING ESTABLISHING A SPECIAL ENROLLMENT PERIOD FOR ENROLLMENT IN AN INDIVIDUAL HEALTH BENEFIT PLAN RELATED TO COVID-19
...This emergency regulation is promulgated and adopted by the Commissioner of Insurance under the authority of §§ 10-1-108(7)(a), (7)(b)(III), 10-1-109(1), 10-16-105(2)(b), 10-16-105.7(3)(a)(II)(G), 10-16-105.7(3)(b)(II)(F),10-16-108.5(8), and 10-16-109, C.R.S.
California's SEP is for uninsured residents who didn't know that the state had reinstated the individual mandate penalty and expanded financial subsidies to those earning 400-600% of the Federal Poverty Line; DC is offering one for those who didn't know they had also reinstated the mandate penalty; and Maryland passed a clever law last year which lets residents check a box when they file their state taxes if they're uninsured which tells the state to contact them to help them enroll.
I concluded that:
...as far as I know, there's nothing preventing other state-based exchanges from establishing Special Enrollment Periods for the coronavirus crisis if they want to.
Coronavirus emergency launches one-month special enrollment period
As part of the state’s overall response to the coronavirus, and in an effort to prioritize health and safety, Maryland Health Connection opened a new special enrollment period for uninsured Marylanders.
When will the special enrollment period begin?
The coronavirus emergency special enrollment period will begin Monday, March 16, and end Wednesday, April 15. Coverage will begin April 1, 2020, regardless of when a health plan is selected during that time period.
Special Enrollment Period (SEP) Available to Purchase Coverage through HealthSource RI as a Part of the State’s Response to COVID-19
Special Enrollment Period will be available through April 15, 2020
EAST PROVIDENCE, R.I. (March 14, 2020) — HealthSource RI has adopted a limited-time Special Enrollment Period (SEP), following Governor Raimondo’s State of Emergency declaration in response to the potential growth of Coronavirus (COVID-19). This SEP will allow uninsured Rhode Islanders to purchase coverage through April 15, 2020. Coverage will begin on the first of the month following the application.
Maryland would use state tax forms to identify uninsured residents and refer them to options for no-cost or low-cost health care under a bill moving forward in the General Assembly.
The bill, if approved, would add a question on state tax returns asking taxpayers if they have health insurance. Those who answer that they don’t have health insurance would be referred to the state's Medicaid program or the health exchange, where individuals can buy health insurance plans.
...Dorn explained to me that the way it would work is much more than that: The state tax returns would include a new line where uninsured filers would be required to check off one of two boxes:
Massachusetts Health Connector offers extended enrollment for uninsured individuals to ease coronavirus fears
BOSTON – March 11, 2020 – To ensure everyone who wants access to covered coronavirus services has it, the Massachusetts Health Connector announced today that uninsured residents can apply and get into coverage through a 45-day window running until April 25.
On March 6, the Division of Insurance announced that Massachusetts health insurers are now required to cover the cost of testing and treatment for members who may be affected by the Coronavirus (COVID-19), including not charging co-pays or deductibles for those services. The Health Connector’s decision to open enrollment to anyone without coverage ensures Massachusetts residents concerned about contracting coronavirus can access necessary services without cost barriers.
Covered California is announcing a special-enrollment period through April 30 to address concerns that many Californians remain unaware of the new financial help or the new state penalty.
Hmmmm....the Special Enrollment Period is interesting. HealthCare.Gov and some state exchanges did something like this in spring 2015 (the first year people had to actually pay the mandate penalty) and managed to get around 210,000 more enrollees nationally. Of course, the penalty for 2014 was only $95 or 1% of income at the time...now it's up to $695/person or 2.5% of household income, so it's a bigger deal.
The court also found that Aliera is a for-profit company and cannot qualify as a health care sharing ministry under state or federal law. The Insurance Department is concerned about potential fraudulent or criminal activity on the part of Aliera. Since the company may be an illegitimate health care sharing ministry, consumers should be aware that if they remain in an Aliera product, they may be covered by an unlicensed insurance company.
Unity Healthshare, now known as OneShare Health, was authorized by the court to reach out to Unity members about their options, and consumers who have purchased a Unity/Aliera product should be aware that they may be receiving this communication.
In early 2018, Maryland state legislators introduced a bill which included a twist on the coverage mandate penalty--those who failed to sign up had another option: They could either pay the penalty or they could choose to have the penalty amount be used to automatically enroll them in the lowest-cost insurance policy available. If they qualified for ACA subsidies, those would even be baked into the equation as well. This was a clever way of softening the blow, while also increasing enrollment and helping out the ACA risk pool.