The federally-facilitated Marketplace (Exchange) went live on October 1, 2013 and has been plagued with difficulties ever since. In recognition of this fact, the Obama administration has given individuals looking to find insurance through the Marketplace a little more time to enroll in coverage that will be effective on January 1, 2014. Originally, someone looking for coverage to be effective on January 1 had to enroll by December 15th. Under the new guidance, an individual has until December 23rd to enroll and receive coverage effective on the first day of 2014.
Why might this be important to employers? It is important to the extent employers are communicating with their employees about their options in the Marketplace. Employees not eligible for an employer-sponsored plan may be looking to their HR department for guidance. In addition, an employer that has traditionally offered a mini-med plan to a group of employees may find itself in the position of communicating regarding the cancellation of those plans and may want to provide information about enrollment options in the Marketplace. It is also important for employers with COBRA participants on their plans. COBRA participants can terminate their COBRA coverage early and enroll in a Marketplace plan during open enrollment. Communicating to COBRA participants about the possibility of less-expensive plans in the Marketplace could be beneficial to both the employer and the former employee.
The rules regarding enrollment and effective dates through the rest of the open enrollment period remain the same. If an individual enrolls on or before the 15th of the month, coverage will begin on the first day of the following month. If an individual enrolls in the later half of the month, the coverage will not be effective until the first day of the second month following. For example, if an individual enrolls in coverage on March 31 (the last day to enroll and not be subject to a fine) the coverage will not be effective until May 1.
Next year, things will be a little different. Open enrollment for the Marketplace in 2014 was originally scheduled to coincide with Medicare open enrollment (October 15 through December 7). However, the Administration has announced that for 2014, open enrollment in the Marketplace will not begin until November 15 and will run through January 15, 2015. The expectation is that in 2015, the Marketplace open enrollment period will change again to align with Medicare open enrollment.
For more details, check out this blog post from Kaiser Health News, and this one from Health Affairs. See also the November 22 Daily Briefing from the White House.
