In which Your Health Idaho is inspired by Douglas Adams.

Over at my 2025 Open Enrollment Period "15 Important Things" guide, I noted the following:

Idaho actually already launched their 2025 Open Enrollment Period on October 15th, and it only runs through December 16th.*

...*Idaho has continued to doing this even though Nov. 1st has almost always been the official start date and the Biden Admin extended the end date out to Jan. 15th several years ago. The Centers for Medicare & Medicaid Services (CMS) issued new rules last year which I had thought were supposed to crack down on this & bring Idaho in line with other states, but apparently the Gem State was grandfathered in.

That last link goes to this entry from October 11th:

Choosing the right coverage for yourself and your family be overwhelming. That’s why we partner with certified agents and brokers, who are available to help you at no cost. To find assistance, click here.

Make sure to enroll in a plan by midnight, December 16, 2024.

Whoa...hold the phone there.

Idaho has been unique among the state-based ACA exchanges the past few years in that they've been launching their annual Open Enrollment Period more than 2 weeks earlier than everyone else (Oct. 15th instead of Nov. 1st) while also ending it a full month earlier than nearly every other state (Dec. 15th instead of Jan. 15th).

However, earlier this year the Centers for Medicare & Medicaid Services (CMS) issued a new rule as part of the annual NBPP which I thought was supposed to line Idaho up with the other states:

The rule also aligns the dates of Open Enrollment periods across almost all Marketplaces to generally begin on November 1 and end no earlier than January 15, with the option to extend the Open Enrollment period beyond January 15.

This one is targeting Idaho and New York: Idaho has been starting their annual Open Enrollment Period 2 weeks earlier (October 15th), which is fine...but they've also been ending it on December 15th, which isn't. Meanwhile, New York has been ending their OEP on January 31st (which is fine)...but they haven't been starting it until November 16th for some reason (which isn't).

However, it looks like I missed a key detail (which I should have noticed given the "generally" caveat above). Louise Norris caught this in her own explainer:

It’s noteworthy that CMS finalized a rule change in 2024 designed to ensure standardization of open enrollment in state-run exchanges. But there was a partial exception for Idaho in the final rule. It clarified that a state-run exchange that began its most recent open enrollment before November 1, 2023, and ended it before January 15, 2024 could continue to begin open enrollment before November 1 and end it before January 15 — but only if the open enrollment period lasts for at least 11 weeks. That rule is clarified in 45 CFR § 155.410(e)(4)(iii).

But Your Health Idaho is still planning to run an open enrollment period that lasts just under nine weeks. It’s unclear how this is in compliance with the federal rules that were finalized in 2024.

In other words, CMS grandfathered Idaho's early start date in since they had already been launching prior to 11/01 when the new rule came out...but they didn't give Idaho their blessing to keep ending it on 12/15, instead requiring them to have the deadline no earlier than New Year's Eve (it's exactly 77 days (11 weeks) from 10/15 - 12/31).

Here's the exact wording of the clarification:

(iii) For any State Exchange with an annual open enrollment period that began before November 1, 2023, and ended before January 15, 2024, for the 2024 benefit year, that State Exchange may continue to begin open enrollment before November 1 for consecutive future benefit years, so long as the open enrollment period continues uninterrupted for at least 11 weeks. If such State Exchange changes the date(s) of their annual open enrollment period, it must comply with paragraphs (e)(4)(i) and (ii) for all future annual open enrollment periods.

Pretty cut & dried, I'd say.

Well, Your Health Idaho did not extend their Open Enrollment Period beyond December 16th...in fact, yesterday they posted on Twitter about Special Enrollment Periods if you missed the deadline & qualify.

In other words, they're very clearly not complying with the CMS requirements.

So, Norris followed up with them and here's what she found out:

"As a state-based exchange, Your Health Idaho has worked closely with our carriers, state, and federal partners, and over 1,200 agents, brokers, and enrollment counselors across Idaho to ensure we find local solutions that meet the needs of our citizens.

"Open Enrollment began on October 1, with anonymous shopping, and ended on December 16th. Anyone who missed that deadline can contact our support center to enroll."

Wow. Just...wow. The first paragraph is, of course, utterly meaningless & irrelevant to the question.

The second is quite the jaw-dropper.

They're counting the entire month of October as being part of the Open Enrollment Period, even though you couldn't actually Enroll during the first two weeks of it. That's like if Target said they were open for business at 5am but their cash registers didn't actually open until 9am.

As for the statement that "anyone who missed the deadline can contact our support center to enroll," aside from that clearly not being remotely the same thing as being able to enroll via the website as one normally would, there's also the tiny little problem that they don't have this posted anywhere on their website, on their Twitter or Facebook feeds, or anywhere else that I know of. In fact, even as I'm typing this, their website lists October 15th - December 15th (not 16th, ironically) as being the Open Enrollment Period:

I was instantly reminded of this classic exchange from the first chapter of The Hitchhiker's Guide to the Galaxy by Douglas Adams:

Mr Prosser: But, Mr Dent, the plans have been available in the local planning office for the last nine months.

Arthur: Oh yes, well as soon as I heard I went straight round to see them, yesterday afternoon. You hadn’t exactly gone out of your way to call attention to them had you? I mean like actually telling anybody or anything.

Mr Prosser: But the plans were on display…

Arthur: On display? I eventually had to go down to the cellar to find them.

Mr Prosser: That’s the display department.

Arthur: With a flashlight.

Mr Prosser: The lights had probably gone out.

Arthur: So had the stairs.

Mr Prosser: But look, you found the notice, didn’t you?

Arthur: Yes yes I did. It was on display at the bottom of a locked filing cabinet stuck in a disused lavatory with a sign on the door saying beware of the leopard.