Special Enrollment Periods & COBRA
Open enrollment opportunities for individual policies (after open enrollment closes)
This applies to individual policies rather than group coverage. The annual open enrollment closed on March 31, 2014 and will re-open on November 15th for a January 1 effective date. Open enrollment for 2015 will run through February 15th and will then close for the remainder of the year. Without a qualifying event individuals are not able to purchase individual health insurance policies.
The new special enrollment periods apply for those who: 1. Are enrolled in or eligible for COBRA; 2. Have individual market plans renewing outside of open enrollment; or are AmeriCorps/VISTA/NCCC members. A hardship exemption applies for all who obtained minimum essential coverage effective on or before May 1, 2014, even if the coverage was purchased without a subsidy.
Under the Affordable Care Act (ACA), individuals may only enroll in health insurance through an Exchange during a permitted enrollment period (such as an open enrollment or a special enrollment period). The initial open enrollment period for Exchange coverage ended on March 31, 2014. The open enrollment period for 2015 will begin on Nov. 15, 2014, and extend through Feb. 15, 2015.
DOL & HHS release New COBRA Guidance for individuals and employers
On May 2, HHS issued a clarifying bulletin profiding an Excahnge special enrollment period for COBRA enrollees. They also updated the model notices which your COBRA administrtor will/should take care of on your behalf.
If you are a group administrator and your plan is COBRA eligible we recommend downloading and reading the COBRA provisions for special enrollment periods. Download your copy here.