April 15 "real" deadline? Not quite...

(sigh) OK, until this morning I was under the impression that the exchange QHP enrollment rules were:

  • 46 states +DC (36 on the Federally-run exchange, plus another 11 of the state-run exchanges): April 15 as long as you started the process by 3/31
  • Oregon: April 30, no "started by 3/31" requirement
  • Nevada: May 30 with the "started by 3/31" requirement
  • Connecticut & Washington State: No extensions

I did know that Florida was allowing paper applications received by April 7 to have their enrollments completed by April 30, but I thought that was it.

Well, if this Motley Fool article is correct, the final numbers could be even a little higher yet:

The new federal deadline -- a special enrollment period – already allowed registrations delayed by exchange-related problems to be finished as late as April 30 for those who submitted a paper application by April 7. That extension applied to individuals living in states where insurance enrollment under the Affordable Care Act is conducted through the federal exchange.

But other extensions are also available in states with their own exchanges, as well as in the District of Columbia. In each case, individuals must have started their application before midnight on March 31. What follow are new dates, as compiled by HealthPocket.

California: April 15
Colorado: May 31
Kentucky: April 15
Maryland: May 1
Massachusetts: April 15 (in special cases, June 30)
Minnesota: May 1
Nevada: May 30
New York: April 15
District of Columbia: April 15

In a number of other states, officials have promised an extension but not specified a new deadline. Others are responding to the logjam by creating a one-on-one special assistance period, supplying consultants to help the individual directly. The states falling into these two categories are Connecticut, Hawaii, Oregon, Rhode Island, Vermont, and Washington. 

Some of these (Maryland and Minnesota) are news to me. Others cause additional confusion due to a lack of detail. For instance:

You have until April 15 to complete your enrollment. If you are waiting for a Medicaid determination, you have until May 31 to enroll in commercial health insurance.

  • Oregon: Motley Fool appears to simply be wrong about this one. Not only are they not doing a "case by case" thing, you don't even have to have started the process by 3/31 to qualify. From the actual Cover Oregon website:

There's more time! Apply by April 30th

Your first step in getting coverage. Start your application now.

I should note that I'm not so sure about Maryland or Minnesota, either. Maryland's exchange website clearly states their "started by 3/31" deadline is April 18, not May 1st (3 more days, but not 2 more weeks). Minnesota's exchange site doesn't say much of anything about either May 1st or even April 15th, so take these with a grain of salt.

As for Massachusetts, I believe the "special cases" rule applies purely to the 200K+ people who are currently in "Limbo Status"; MA received a special waiver that allows these folks to be placed on some sort of temporary coverage until the mess is sorted out. I suppose it's conceivable that these people may end up putting the total exchange QHP tally over the 8M mark, but I'm not holding my breath.

In addition, it looks like the April 30 rule for paper applications received by April 7 does apply to all 36 federally-run states, which makes sense.

And finally, of course, there's the "Major Life Events", SHOP enrollments, Native American exception and Medicaid enrollments, none of which have any deadline at all.

There are exceptions to the ACA enrollment window for "qualifying" events during the period in which enrollment is closed. These include moving, getting married or divorced, and losing your group coverage. Under such circumstances, you should be able to acquire new ACA-compliant insurance under the terms of the law.