Well, today I received a likely answer which is depressing but not surprising at all: According to my sources, there isn't any technical, logistical, personnel or support reasons why HealthCare.Gov couldn't launch a formal COVID-19 Special Enrollment Period at any time. The only logical conclusion is that the White House has decided not to allow one for political reasons.
...The more people who come to rely on the Affordable Care Act--especially the ACA exchange operated by the Trump Administration itself--the more difficult it's going to be to justify the Trump Administration continuing to support a lawsuit with the sole purpose of attempting to have the ACA struck down by the Supreme Court...which they're continuing to try and do even in the middle of a pandemic.
Over the next week or so, more and more of the 13 state-based ACA exchanges announced just such a COVID-19 SEP; eventually 12 out of 13 state-based exchanges did so (Idaho is the odd man out), and eventually even the health insurance industry (which is normally opposed to allowing exceptions to the official Open Enrollment Period) were onboard with a COVID SEP. Two weeks ago I was 95% certain that HC.gov would be announcing one at any moment.
And then...nothing. Nothing last week. Nothing yesterday. Nothing as of this writing.
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.
Former Wyoming Blackjewel LLC coal miners who have been out of work since July 1 and without health insurance since their group health plan was canceled Aug. 31 can sign up for the federal health insurance marketplace retroactively to Sept. 1.
The Wyoming Department of Insurance has successfully lobbied the Centers for Medicare and Medicaid Services (CMS) to make an “exceptional circumstances” special enrollment period through Oct. 30, said Denise Burke, an attorney with the state Department of Insurance.
The exception allows former Blackjewel coal miners an option to buy health insurance off the marketplace and made it retroactively effective to Sept. 1, which means workers and family members with ongoing health issues can continue treatment as if they never lost insurance.
Back in January I reported that the state of Colorado is joining several other states in cracking down on non-ACA compliant so-called "Short-Term, Limited Duration" healthcare policies. As of April 1st, STLDs:
Can last no longer than 6 months/year (still longer than the 3-mo limit under Obama)
Have to stick to the ACA's 3:1 age band limit on premiums
Must be guaranteed issue (no more medical underwriting)
They can still exclude coverage of pre-existing conditions, but there's a limit of 12 months on the lookback timeframe
Must cover all 10 of the ACA's Essential Health Benefits
Must follow other ACA community rating requirements (limiting variances to age, tobacco use and geographic area)
A minimum Medical Loss Ratio of 80% to match the ACA's MLR (currently CO only requires a 60% MLF)
In other words, Colorado just made STLDs follow most of the same rules as ACA-compliant policies.
Back in early December, I noted that while I applauded both New Jersey and the District of Columbia for creating their own individual healthcare coverage responsibility requirements (aka, The Individual Mandate) in response to Congressional Republicans repealing the ACA's federal penalty, doing so also required making sure that residents of NJ/DC *knew* they had done so:
There's only one problem with this: The impact of the mandate penalty is completely psychological in nature. It only works (to the extent that it does at all) if people know that they'll be penalized financially for not complying with the mandate.
On another note, I also want to use this as an opportunity to point out that maintaining quality health insurance coverage needs to be a priority year in and year out. Jenks notes that "Pregnancies are often unplanned, making limited enrollment periods impractical for many women." But can't that be said of any medical condition? In fact, I would say pregnancy is one aspect of healthcare that's probably much more likely to actually be planned. While about half of pregnancies are planned, I doubt the same could be said for cancers, heart attacks, or car accidents.
In other words, while not all pregnancies are planned, overall it's a lot less "random" than most other expensive healthcare incidents.