Extended open enrollment periods: a state by state guide

by Amy

For many places across the country, December 15th is the last day to sign up for health coverage for a January 1st start date. Like anything, this deadline comes with a few exceptions. Certain states have extended open enrollment periods, giving their residents a little extra time to make decisions for 2021 coverage.

**This post is updated daily to reflect deadline changes as they are announced.** 

We've put together this handy guide just for you to determine the last possible date you can sign up for a health insurance plan based on when you want your coverage to start. Most of you are looking for January 1st coverage. In some cases, while there is an extended enrollment period that reaches into January, that means your health plan won't start until February 1st.

Important: If you are receiving reimbursements for health insurance through your employer with either an ICHRA or QSEHRA (two types of HRAs), a February start date for your health plan will mean your reimbursements will begin in February as well. 

We'll have a few state-level updates to marketplaces and exchanges, as well as carrier-specific updates that will come in today and later this week. Stay tuned!

States with extended open enrollment periods

Each state marketplace can set their own dates, meaning they don't have to comply by the December 15th cutoff if they don't want to. The states that have extended their open enrollment periods for their residents include: California, Colorado, Massachusetts, Minnesota, Nevada, New Jersey, New York, Pennsylvania, Rhode Island, Washington, and Washington D.C. That means if you live in one of those states, you have more time to consider your health insurance options for 2021 than the rest of the country. 

Here's a chart summarizing key deadlines from open enrollment for those states. 

Open enrollment deadlines by state: 

State Extended open enrollment dates  Deadline for 1/1 start Deadline for 2/1 start
California 11/1/20 - 1/31/21 12/30/20 1/31/21
Colorado 11/1/20 - 1/15/21 12/18/20 1/15/21
D.C. 11/1/20 - 1/31/21 12/15/20 1/31/21
Idaho 11/1/20 - 12/31/20 12/31/20  
Massachusetts 11/1/20 - 1/23/21 12/23/20 1/23/21
Minnesota 11/1/20 - 12/22/20 12/22/20  
Nevada 11/1/20 - 1/15/21 12/31/20 1/15/21
New Jersey 11/1/20 - 1/31/21 12/31/20 1/31/21
New York 11/1/20 - 1/31/21 12/15/20 1/31/21
Pennsylvania 11/1/20 - 1/15/21 12/22/20 1/15/21
Rhode Island 11/1/20 - 1/23/21 12/31/20 1/23/21
Washington 11/1/20 - 1/15/21 12/15/20 1/15/21

If you don't see your state listed in the chart above, then assume the default open enrollment deadline is December 15th. 

What happens if I miss the deadline for open enrollment? 

Don't panic. You might have options, depending on what type of HRA you are being offered through your company!

If your employer offers you a QSEHRA, our team can help you look into alternative plans (like sharing ministries, for example) to couple with an individual / preventative MEC plan. These costs will be reimbursable through your QSEHRA.

Here's an important note about the timing. For a February 1 start date, assume that you'll need to enroll before the 30th of January. There's important exceptions here, like Blue Cross Blue Shield, for example, which requires enrollment on the 15th of the previous month. Take into consideration these dates as you're looking to enroll in an alternative plan or if you've qualified for a special enrollment period. More on that in a minute.  

If you are being offered an ICHRA, check to see if you qualify for a special enrollment period. Here's a full list.

Changes in household

You may qualify for a Special Enrollment Period if you or anyone in your household in the past 60 days:

  • Got married.
  • Had a baby, adopted a child, or placed a child for foster care. Your coverage can start the day of the event — even if you enroll in the plan up to 60 days afterward.
  • Got divorced or legally separated and lost health insurance. Note: Divorce or legal separation without losing coverage doesn’t qualify you for a Special Enrollment Period.
  • Death. You’ll be eligible for a Special Enrollment Period if someone on your Marketplace plan dies and you’re no longer eligible for your current health plan as a result of their death.

Changes in residence

  • Household moves that qualify you for a Special Enrollment Period:
  • Moving to a new home in a new ZIP code or county
  • Moving to the U.S. from a foreign country or United States territory
  • A student moving to or from the place they attend school
  • A seasonal worker moving to or from the place they both live and work
  • Moving to or from a shelter or other transitional housing. You must prove you had health coverage for one or more days during the 60 days before your move. You don’t need to provide proof if you’re moving from a foreign country or United States territory.

Loss of health insurance

  • If you or anyone in your household lost qualifying health coverage in the past 60 days OR expects to lose coverage in the next 60 days.
  • Losing job-based coverage
  • Losing individual health coverage for a plan or policy you bought yourself. There are several carriers leaving certain states or the entire individual market altogether.
  • Losing eligibility for Medicaid or CHIP
  • Losing eligibility for Medicare
  • Losing coverage through a family member

Additional qualifying changes

  • Changes that make you no longer eligible for Medicaid or the Children’s Health Insurance Program (CHIP)
  • Gaining membership in a federally recognized tribe or status as an Alaska Native Claims Settlement Act (ANCSA) Corporation shareholder
  • Becoming newly eligible for Marketplace coverage because you became a U.S. citizen
  • Leaving incarceration
  • AmeriCorps VISTA members starting or ending their service

If you don't qualify for a special enrollment period due to one of the above circumstances, your best bet is to just choose an alternative plan of insurance (sharing ministry, short-term plans). Unfortunately, these alternatives won't be reimbursable under your company's ICHRA. You'll need to wait until next year's open enrollment to choose a compliant health plan to receive reimbursements. 


We are here to help!

Get in touch with our team to sign up for a plan to use with your employer's HRA. We will walk you through your options. Just chat with us at the bottom right of your screen. You can also email us at support@takecommandhealth.com. We'd be happy to help you.

Happy open enrollment!

Picture of Amy

Hi, I'm Amy! I wrote this blog because I care about ideas (big and little) that can help fix our healthcare system. I used to work on projects for Kaiser Permanente and the Parkland Health & Hospital System so I've seen the system inside and out. It's so important that consumers keep up with industry shifts and changing health insurance regulations. I'm also Take Command Health's Content Editor and a busy mom. Learn more about me and connect with me on our about us page. Thanks!