Families choosing individual coverage through an insurance Exchange would have less time under a proposal CMS published on February 17, 2017. The agency wanted enrollment for the 2018 plan year to run from November 1 through December 15, 2017, instead of continuing through January 31, 2018. The proposal had not itself replaced the existing calendar. [2017-03027][2016-04439]

The distinction matters for people comparing when to choose with when coverage begins. The March 2016 final rule already assigned January 1 coverage to selections received by December 15. Later selections carried February or March start dates. Moving the closing date would narrow the selection window; it would not turn an annual plan into a shorter insurance policy. [2017-03027][2016-04439]

CMS intended extensive outreach and argued that an earlier finish would simplify operations and support a full year of coverage. But its own impact analysis warned that insufficient support for Exchanges and enrollment assisters could mean longer waits and additional enrollment losses. Government, state Exchanges and insurers might also incur costs for extra consumer outreach. [2017-03027]

The public-interest test is therefore more concrete than whether a deadline looks tidy: could people complete their choices within it? CMS also acknowledged possible losses among younger, healthier people who tended to enroll late, complicating its hoped-for reduction in adverse selection. These were competing possibilities, not observed results. The two official documents trace one agency policy history, rather than independently proving that the shorter window would work. [2017-03027][2016-04439]

Source documents

  1. Patient Protection and Affordable Care Act; Market Stabilizationhttps://www.govinfo.gov/content/pkg/FR-2017-02-17/html/2017-03027.htm
  2. Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2017https://www.govinfo.gov/content/pkg/FR-2016-03-08/html/2016-04439.htm