CMS proposed a different closing date for 2018 Exchange enrollment on February 17, 2017. Under the existing rule, the window would open November 1, 2017, and close January 31, 2018. The proposal retained the opening date but moved the finish to December 15, 2017. It was a proposed amendment, not a completed change. [2017-03027][2016-04439]

The March 8, 2016 final rule supplies the baseline. It kept the November-to-January window for benefit years 2016, 2017 and 2018, then scheduled a November 1–December 15 window for 2019 and later benefit years. Thus the new proposal sought to bring forward an existing calendar design, rather than introduce an entirely unfamiliar enrollment season. [2017-03027][2016-04439]

Enrollment and coverage dates answer different questions. The 2016 provision made coverage effective January 1 for selections received by December 15, February 1 for selections from December 16 through January 15, and March 1 for January 16–31 selections. CMS said selections within its proposed 2018 window would receive a January 1, 2018 effective date. A shorter opportunity to enroll was not a shorter duration of coverage. [2017-03027][2016-04439]

CMS expected simpler operations and less opportunity for people to enroll after discovering a need for services late in December or January. Its impact analysis also identified the opposite pressure: fewer younger, healthier late enrollees could join. Those possibilities do not establish a net improvement. The documents belong to one agency policy chain and explain the mechanism, not its eventual effects on enrollment or premiums. [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