UPDATE: Extensions for some in Colorado & Washington State

The final 2016 deadline to enroll in a qualifying healthcare plan for policies starting coverage as of March 1st officially ended as of MIDNIGHT on January 31st.

As usual however, there are a few caveats to this...but not as many as the past two years:

  • Those who lost coverage as of 12/31/15 due to their policies being discontinued by their insurance carrier still have until February 29th to enroll. This includes:
    • Anyone who was enrolled in a policy through one of the 10 Co-Ops which shut down as of 12/31/15.
    • Wyoming residents who were enrolled in policies via WINhealth
    • Residents of any state who were enrolled in a policy via Assurant
    • Colorado & Oregon residents who were enrolled in discontinued "Transitional" policies
    • Colorado residents who were enrolled in policies via Rocky Mountain Health Plans in areas where RMHP no longer services
    • In general, any other policy which was terminated when the enrollee wasn't responsible for the termination (in other words, if your policy was cancelled becaus you chose to cancel it, didn't pay your premiums, etc., then that obviously doesn't count; here's the official legalese defining the circumstances) (h/t to Louise Norris for the link)

HOWEVER, they'll have to make sure to invoke the Loss of Coverage Special Enrollment Period provision in order to do so.

IMPORTANT: Unlike last year, HealthCare.Gov will not be offering a "Tax Filing Season" SEP this year (aka #ACATaxTime). If the only reason you didn't make the deadline is because you "didn't know" about the $695/person (or 2.5% of household income) tax penalty, you're out of luck this year. It's conceivable that a few of the state exchanges may offer one, but I doubt it.

In addition, there are a number of additional SEP situations which are no longer being allowed this year, though I don't think these applied to too many people in the first place:

  • Consumers who enrolled with too much in advance payments of the premium tax credit because of aredundant or duplicate policy
  • Consumers who were affected by an error in the treatment of Social Security Income for tax dependents
  • Lawfully present non-citizens that were affected by a system error in determination of their advance payments of the premium tax credit
  • Lawfully present non-citizens with incomes below 100% FPL who experienced certain processing delays
  • Consumers who were eligible for or enrolled in COBRA and not sufficiently informed about their coverage options
  • Consumers who were previously enrolled in the Pre-Existing Condition Health Insurance Program

In addition, CMS is supposedly cracking down on off-season SEP enrollment verification this year with some sort of sporadic auditing program. As far as I can tell, they plan on flagging suspicious SEP requests and requiring documentation to prove that the enrollee actually qualifies for the SEP, which is more than reasonable.