The calendar rules everything
Every date that decides the plan year
Health insurance is one of the few products where the deadline is more binding than the price. Miss January 15 without a qualifying life event and the next ordinary chance to enrol is eleven months away.
The plan year, in order
From rate filing to reconciliation
The consumer-facing part of the year is eleven weeks long. The rest of it is carriers, regulators and agents preparing for those eleven weeks.
Apr - May
Carriers
Rate filings
Carriers file proposed rates and plan designs with state regulators for the following plan year.
Jun - Aug
Regulators
Rate review
State departments of insurance review and often reduce proposed increases. Filings become public.
Sep
CMS
Landscape files
Plan and rate landscape files are published. Our index is rebuilt within 48 hours of release.
Aug - Oct
Agents
FFM registration
Annual CMS Marketplace training and the two agent-broker agreements must be completed before Nov 1.
Nov 1
Everyone
Open Enrollment opens
The Marketplace opens for the following plan year. Window shopping usually opens about a week earlier.
Dec 15
Consumers
January 1 deadline
Enrol or change plans by this date for coverage effective January 1. The busiest single day of the year.
Dec 16 - Jan 15
Consumers
February effective dates
Enrolments completed in this stretch take effect February 1, leaving a one-month gap.
Jan 15
Everyone
Open Enrollment closes
The federal window closes. After this, only a qualifying life event opens a special enrollment period.
Jan 31
Marketplace
Form 1095-A issued
The Marketplace statement for the prior plan year is issued to every enrolled household.
Feb - Apr
Consumers
Reconciliation
Advance premium tax credits are reconciled against actual income on IRS Form 8962.
All year
Qualifying households
Special enrollment
Marriage, birth, a move, or loss of other coverage opens a 60-day window at any point in the year.
Not everywhere is the same
State-based exchanges set their own dates
Seventeen states and the District of Columbia run their own marketplace. Several of them keep enrollment open past the federal deadline, which is the single most useful piece of information for anyone who missed January 15.
| Jurisdiction | Open Enrollment closes | Note |
|---|---|---|
| California | January 31 | State-based exchange, extended window |
| District of Columbia | January 31 | State-based exchange |
| Idaho | December 15 | Opens and closes earliest in the country |
| Massachusetts | January 23 | State-based exchange |
| New Jersey | January 31 | State-based exchange |
| New York | January 31 | State-based exchange |
| Rhode Island | January 31 | State-based exchange |
| All FFM states | January 15 | The federal window |
Illustrative selection. Confirm against your own state exchange each plan year.
A household that misses the federal deadline should check whether their state runs its own exchange before assuming the year is closed.1
Outside the window
What still opens a door after January 15
Special enrollment is not a loophole. It is the part of the statute that acknowledges that lives change in February.
| Qualifying life event | Window | Coverage starts |
|---|---|---|
| Loss of job-based coverage | 60 days before and after | First of the following month |
| Marriage | 60 days after | First of the following month |
| Birth or adoption | 60 days after | Date of the event |
| Permanent move | 60 days after | First of the following month |
| Loss of Medicaid or CHIP | 60 days before and after | First of the following month |
| Divorce with loss of coverage | 60 days after | First of the following month |
| Gaining lawful presence | 60 days after | First of the following month |
| Income change to under 150% FPL | Monthly, where available | First of the following month |
Voluntarily dropping other coverage does not open a special enrollment period, and neither does changing your mind about a plan already chosen.
For agents
Your own deadlines, which nobody sends you
An agent's calendar runs about ten weeks ahead of the consumer's. Everything that matters happens before November 1.
- August
CMS Marketplace training opens
Complete it early. The queue in late October is the reason agents miss Nov 1.
- September
Landscape files publish
Rebuild your quoting index and re-check every carrier's footprint for exits.
- October
Appointments and licences verified
Resident and non-resident, per carrier, per state, with expiry dates recorded.
- October 15
Renewal book triaged
Rank by exposure: benchmark moves, discontinued plans, credit falls. Call in that order.
- February
Commission reconciliation
Match January statements against the book. Chase every policy in force and unpaid.
Next
Put the dates somewhere you will see them.
Or let the desk do it. Households on our book get reminders before December 15 and before January 15, and nothing else.