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Is the open enrollment period the same for Medicare and the Marketplaces?

There is some overlap in the enrollment periods for Medicare and the Marketplaces, but this year they are not the same.  The Medicare open enrollment period runs from October 15 through December 7 each year.  For Marketplace coverage in 2019, the open enrollment period will run from November 1, 2018 through December 15, 2018 in states that use the HealthCare.gov website.  Some states that run their own Marketplaces will have a somewhat longer Open Enrollment period for 2019 coverage.  Check with your state Marketplace for more information.

If you are covered by Medicare, and you are interested in reviewing and comparing your Medicare coverage options, make sure the plans you are considering during the open enrollment period are Medicare plans, not Marketplace plans.  Medicare plans are not sold through the federal or state Marketplace websites.  You can review and compare your Medicare options on the Medicare website (www.Medicare.gov) or by calling 1-800-MEDICARE.

I have COBRA and am finding it hard to afford, but Open Enrollment is over. Can I drop my COBRA and apply for non-group coverage outside of Open Enrollment?

No, voluntarily dropping your COBRA coverage or ceasing to pay your COBRA premiums will not trigger a special enrollment opportunity. You will have to wait until you exhaust your COBRA coverage or until the next Open Enrollment (whichever comes first) to sign up for other non-group coverage.

I have COBRA and it’s too expensive. Can I drop it during Open Enrollment and enroll in a Marketplace plan instead?

During Open Enrollment, you can sign up for a Marketplace plan even if you already have COBRA.  You will have to drop your COBRA coverage effective on the date your new Marketplace plan coverage begins.  After Open Enrollment ends, however, if you voluntarily drop your COBRA coverage or stop paying premiums, you will not be eligible for a special enrollment opportunity and will have to wait until the next Open Enrollment period.  Only exhaustion of your COBRA coverage triggers a special enrollment opportunity.

My 26th birthday is next week and I will lose coverage under my parent’s plan at the end of this month. Open Enrollment has closed. What do I do now?

You should act now to review your coverage options and sign up for new coverage. You may have more than one option.

If your parent’s plan was offered by an employer with more than 20 workers, you will probably be offered COBRA.  This is an option to continue coverage under the plan for up to 36 months.  COBRA coverage is typically an expensive option because your parent’s employer is no longer required to contribute to the premium, but it may be important option for some young adults, for example, if you are currently in treatment for a condition and prefer not to change coverage now.

You should have or will soon receive a notice from your parent’s plan that your dependent status is about to end and informing you of your right to elect COBRA.  You have 60 days from the latter of that notice or the date dependent coverage ends to elect or decline COBRA coverage.  If you elect COBRA, you have up to 45 days to pay the first premium (COBRA coverage will be effective on the first day after your dependent coverage ended, so the first premium will cover the time retroactive to that date.)  If you don’t make the first payment on time, your COBRA election will not take effect.

Once you elect COBRA and pay the first premium, you will not be eligible to apply for a Marketplace plan with tax credits until the next Open Enrollment period.  Even though COBRA lasts 36 months, you do have the option during each Open Enrollment period to drop COBRA and apply instead for subsidized Marketplace coverage.

The Marketplace is another option to consider.  Premium tax credits subsidize the cost of Marketplace coverage if your income is between 100% and 400% of the federal poverty level, so for many young adults, this option may be more affordable.  Generally people can only apply for Marketplace coverage during Open Enrollment.  However, loss of dependent status under your parent’s plan is a qualifying event that makes you eligible for a special enrollment period (SEP).  Your SEP lasts 60 days from the date of your qualifying event (the day your parent’s coverage ends) but when the coverage loss can be anticipated, you can also apply for new coverage up to 60 days before your qualifying event.  Acting early makes it more likely you won’t have a gap in coverage.

You can apply for Marketplace coverage on your own or ask for help from a Navigator or other Marketplace assister program.  Indicate on the Marketplace website that you are applying for coverage during a SEP and make your plan selection.  In federal Marketplace states, you will be required to provide proof of your qualifying event before your new coverage will take effect.   For example, if you were also eligible for COBRA under your parent’s plan, submitting a copy of your COBRA notice can document your eligibility for the SEP.  Healthcare.gov will give you 30 days from the date you select your new plan to provide proof of your other coverage loss.  It is very important to act quickly to complete this verification process.  If you do not submit the required documentation within 30 days, your plan selection will be cancelled and you will no longer be eligible for the SEP.

Finally, if your income is very low, you might qualify for Medicaid.  Medicaid is open for enrollment year round and, in more than half of the states, will cover adults with income up to 138% of the poverty level (about $16,753 for a single person in 2019.)  You can also apply for Medicaid through the Marketplace and can get help with your application from a Navigator or other in-person assistance program.

I’m covered as a young adult dependent on my parent’s policy now, but my 26th birthday is next summer, at which point I won’t be eligible for dependent coverage any longer. Should I apply for Marketplace health plans and subsidies now, during Open Enrollment?

You can remain covered as a dependent on your parent’s policy until you turn 26. Once you lose eligibility as a dependent, you will qualify for a special enrollment opportunity. At that point, you will also be able to apply for health coverage and assistance through the Marketplace, even though it won’t be during a regular Open Enrollment period.  In addition, if your parent’s policy is a group plan offered by an employer with at least 20 workers, you would also be able to continue coverage under the policy through COBRA for up to 3 years.  However, the employer contribution to the premium would end and Marketplace subsidies cannot be applied to the COBRA coverage.

I am self-employed with uneven income. When I applied for premium tax credits during Open Enrollment, I said I expect to earn much less next year than I did last year. The Marketplace said I must provide more documentation but didn’t say what to send. How can I find out?

Unfortunately, in most states so far, the data match inconsistency notices are not very specific in describing the additional documentation that is required.  Instead, notices list generic types of types of income documentation without specifying the documentation appropriate for you.  If you are self-employed and estimate your income next year will be significantly less than what you reported on your most recent tax return, you should provide copies of any documents that support your estimate.  Make sure to provide copies and not original documents.  If you don’t have documents, a signed statement explaining your estimate may be accepted.  Be sure to include your name and ID number, a description of the income you expect to earn next year, a description of how you arrived at your estimated income amount, and an explanation of why other documentation is not available.

I didn’t apply for a hardship exemption from the Marketplace during Open Enrollment. Is it too late to apply for a hardship exemption for this year?

No, you can apply to the Marketplace for a hardship exemption at any time during the year.  Most hardship exemptions will be granted for the month before the hardship, the months of the hardship, and the month after the hardship. You will need to document the timing of the hardship in your application.

In addition, for the 2018 tax year, you can claim a hardship exemption directly on your tax return, by checking the box on Form 1040, without having to apply to the Marketplace.  You won’t be required to submit documentation of the hardship with your tax return, though you should retain any documents for your own records.

I have COBRA and am finding it difficult to afford, but Open Enrollment is over. Can I drop my COBRA and apply for non-group coverage outside of Open Enrollment?

No, voluntarily dropping your COBRA coverage or ceasing to pay your COBRA premiums will not trigger a special enrollment opportunity. You will have to wait until you exhaust your COBRA coverage or until the next Open Enrollment (whichever comes first) to sign up for other non-group coverage.

I have COBRA and it’s too expensive. Can I drop it during Open Enrollment and enroll in a Marketplace plan instead?

During Open Enrollment, you can sign up for a Marketplace plan even if you already have COBRA. You will have to drop your COBRA coverage effective on the date your new Marketplace plan coverage begins. After Open Enrollment ends, however, if you voluntarily drop your COBRA coverage or stop paying premiums, you will not be eligible for a special enrollment opportunity and will have to wait until the next Open Enrollment period. Only exhaustion of your COBRA coverage triggers a special enrollment opportunity.  

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