Q. If I sign up for a Bronze plan during open enrollment, can I bump my coverage up to a higher level several months later if I find out that I need surgery?
Thanks to the American Rescue Plan, premium subsidies are larger and available to more people in 2021 and 2022.
A. In general no, although it might be possible depending on the circumstances.
Although the COVID-related enrollment window ended on August 15, 2021 in most states, it’s still ongoing in some states.
Regardless of where you live, if you experience a qualifying event, you may be able to switch to a different plan — but a need for medical care is never a qualifying event, and rules that HHS finalized in 2017 limit the ability to switch to a plan at a different metal level outside of open enrollment.
The American Rescue Plan has enhanced premium subsidies for 2021 and 2022, and made robust coverage available at no cost for people receiving unemployment compensation in 2021. Although the COVID/American Rescue Plan enrollment window has ended in most states, you may still be able to switch to a zero-cost Silver plan with robust benefits if you’ve received unemployment compensation this year. In Minnesota, for example, that’s still possible, and it’s still possible in some of the few states where the COVID-related special enrollment period continues past August 15, 2021.
But in general, the normal rules are once again in place in most of the country: Plan changes are only possible during open enrollment and special enrollment periods triggered by a qualifying event. These rules apply both on and off-exchange. So regardless of whether you buy your health insurance plan through the exchange or outside the exchange, you won’t have an opportunity to switch to a different plan until the following year (during open enrollment) unless you experience a qualifying event. And the rules that mostly limit people to plan changes within the same metal level are applicable to most qualifying event-related plan changes.
Open enrollment for 2022 health coverage will begin November 1, 2021. During that window, which is expected to last through January 15, 2022, you’ll have an opportunity to switch to any plan you like, at any metal level. But then once open enrollment closes, your ability to switch to a different plan later in 2022 will once again be sharply limited.
The American Rescue Plan’s subsidy enhancements will continue to be available throughout 2022, so the Gold plans you see for sale during the open enrollment period in the fall of 2021 may be less expensive than the Gold plans you saw in the fall of 2020, before the American Rescue Plan had been implemented. This might make it easier to select a more robust plan for 2022.
Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.
