2020 OPEN ENROLLMENT ENDS (most states)

Time: D H M S

Minnesota announces shorter Open Enrollment Period this year

Long-time readers may have noticed that, while I've obviously ripped on the Trump Administration a lot for the various ways they've screwed around with administration of the ACA over the past 2 1/2 years, there's a handful of actions they've taken which I haven't criticized them for...or at least, which I've been fairly circumstpect about being too critical about.

The biggest, and perhaps most surprising, of the latter is the Centers for Medicare & Medicaid (CMS) decision to shorten the offiical Open Enrollment Period (OEP) roughly in half, from three months (Nov. 1st - Jan. 31st) down to just six weeks (Nov. 1st - Dec. 15th). There's a couple of reasons for this.

First and foremost...the Obama Administration was already planning on shortening the period...it's just that they intended to make the change starting in 2018 instead of 2017. This is from February 2016, long before Trump even secured the GOP nomination:

Annual Open Enrollment Period: We are finalizing the open enrollment period for the individual market Marketplaces for benefit years 2017 and 2018 to correspond to the open enrollment period for the 2016 benefit year, meaning it will begin on November 1 of the year preceding the benefit year and run through January 31 of the benefit year. We also finalized the open enrollment period for benefit year 2019 and later benefit years, so that it will begin on November 1 and run through December 15 of the year preceding the benefit year. This policy will provide continuity in the short run and sufficient time for all entities involved in the annual open enrollment period process, including Exchanges and issuers, to make the necessary adjustments to meet this earlier deadline.

In other words, the "sins" Tom Price and Seema Verma are guilty of on this particular issue are: 1) moving the "half-length OEP" change up by one year, and 2) slashing the marketing/outreach budget by 90%, which of course meant that far fewer people heard about the shortened enrollment period. However, the decision to eventually shorten the period itself was already baked in, so I can't gripe too much about that.

As for why it was shortened, well, that goes back to the part of the 3-Legged Stool's "Red Leg" which most people don't talk too much about. If the Green Leg is the carrot (financial assistance, etc.), the Red Leg is the "stick"...the stuff which enrollees grumble about. It consists mainly of two parts: The Individual Mandate penalty (which has, of course, been zeroed out by the GOP for most states)...and the limited-time Open Enrollment Period.

The point of the mandate penalty is (was) obvious: It prods people into enrolling at all, or face a financial penalty. By "encouraging" healthy people to enroll, the risk pool is improved and premiums are kept lower (not low, but lower...zeroing out the mandate penalty caused premiums to increase an extra 8% or so on average nationally this year).

The limited-time Open Enrollment Period serves a slightly different function: It prevents people from gaming the system by waiting until they're actually sick/injured before enrolling in coverage...which hurts the risk pool, the same way that letting people buy auto insurance after they crash their car or homeowner's insurance after their house catches on fire would cause premiums to skyrocket in those markets.

For this reason, aside from a specific list of qualifying life events which allow for exceptions (getting married/divorced, having a baby, losing another type of coverage, etc), you have to enroll within a certain time window or else you lose the ability to do so until the following year. The shorter the enrollment period, the thinking goes, the harder it is for people to game the system by strategically timing their enrollment.

There's nothing controversial about this practice--it's pretty standard with most employer-sponsored insurance (for employees who want to change their policy to a different one) as well as Medicare (if you want to make a change to your plan). The ACA's 6-week Open Enrollment Period is shorter than Medicare Open Enrollment, but it's several weeks longer than most employer-sponsored insurance plans, which typically run from two to four weeks.

On the other hand, there's a major difference: With Medicare and employer policies, the open enrollment period is only for current enrollees considering changing their policy, whereas the ACA is also for new enrollees, and while many employers are limited to a single rating area or state, the ACA exchanges enroll people from all 50 states + DC, so there's a lot more factors to consider. In other words, there are strong arguments to be made for both shorter or longer.

With all that in mind, while HealthCare.Gov has locked things in at 6 weeks for several years now, some of the state exchanges (13 of them starting this year, now that Nevada has split off onto their own platform) have stuck with longer OEPs. Three exchanges (California, New York and the District of Columbia) are keeping to the full 3-month schedule (in fact, California's OEP is technically starting on October 15th, but only for current enrollees looking to renew coverage). Other states like Rhode Island, Massachusetts and Colorado have experimented with OEPs which run somewhere in between.

Minnesota, which was among those with extended OEPs in the past, is shortening things a few weeks this year, but is still allowing some extra time:

Today MNsure announced that Minnesotans will have seven weeks – from Friday, November 1, 2019, to Monday, December 23, 2019 – to shop for 2020 health coverage. Minnesota’s enrollment period is eight days longer than the federal open enrollment period that runs from November 1 to December 15. MNsure is supplementing the federal open enrollment period with a special enrollment period to give Minnesotans more time to find a health insurance plan that works for them.

"This year, Minnesotans will have seven weeks to sign up for health and dental coverage with an effective date of January 1, 2020," said MNsure CEO Nate Clark. "It’s important to be covered all twelve months of the year. We’re here to help make sure consumers are able to choose a plan and enroll by the December 23 deadline so they can start using their coverage right away in the new year."

It's worth noting that this is actually closer to 8 weeks than 7 (and while I'm at it, 11/1 - 12/15 is actually 6 1/2 weeks).