Availability of short-term health insurance in Washington

No. LifeMap (part of USAble Life) used to offer short-term health plans in Washington, but they stopped doing so in mind-2022. The Washington Office of the Insurance Commissioner confirmed in September 2022 that there were no longer any insurers offering short-term health insurance in Washington, and that is still true as of 2023.

That may or may not change in the future. LifeMap had been the only insurer selling short-term plans in Washington for several years. It’s possible that other insurers might start offering short-term plans in the state, but they would have to conform to the state’s fairly strict rules (described below).

The new rules for short-term health insurance in Washington State, effective January 2019, limit the short-term plan duration to no more than three months in length and prohibit renewals. Previously, the duration of short-term coverage in Washington State was not restricted beyond federal regulations, although such plans had to officially be determined to be short-term limited-duration plans by the Insurance Commissioner and approved prior to being offered for sale. (See RCW 48.43.005 (26)(l).)

Until October 2, 2018, federal regulations limited short-term health plans to no more than three months, and renewals were prohibited. But the Trump administration’s rules for short-term plans (effective October 2, 2018) allow them to have initial terms of up to 364 days, and a total duration (including renewals) of up to 36 months.

Although the federal rules changed on October 2, 2018, and Washington’s new rules didn’t take effect until January 2019, the Office of the Insurance Commissioner confirmed that LifeMap, the only insurer selling short-term plans in Washington in 2018, did not submit filings for any longer-term short-term plans to be sold in the final quarter of 2018. So although longer short-term plans were allowed under federal rules in late 2018 and were not banned under state rules until 2019, the only plans available in Washington in 2018 were limited to three months in duration, and that has continued to be the case ever since.

As noted above, LifeMap discontinued its short-term plans in mid-2022, and there are no longer any short-term plans for sale in Washington state.

Since mid-2022, there have not been any insurers that offer short-term health insurance in Washington. LifeMap previously offered these plans, but discontinued them in July 2022.

Consumers in Washington can buy ACA-compliant health insurance through the state’s marketplace, Washington Healthplanfinder. Twelve carriers offer coverage through the exchange in 2023, and all of them plan to continue to do so in 2024.

ACA-compliant plans are purchased on a monthly basis, so you can enroll in coverage even for only a few months until another policy takes effect — and if you’re eligible, you may qualify for financial assistance in the form of a premium subsidy.

Washington residents may also be eligible for Medicaid coverage.

The relaxed federal regulations implemented by the Trump administration in 2018 (allowing short-term plans to have longer durations) are clear in noting that states may impose tighter regulations. And Washington’s insurance commissioner, Mike Kriedler, who has called short-term plans “a poor solution for consumers,” announced in March 2018 that his office would begin the process of rule-making to define short-term plans at the state level.

An outline of the proposed regulations was published in June 2018. The official draft regulation notice was published on August 21, 2018, and public comments were accepted until September 24, 2018.

The rule was officially adopted in October 2018. It was adopted as proposed, except the rule requiring 20 days’ notice before a rescission or cancellation was adjusted for circumstances in which there are fewer than 20 days remaining in the plan’s duration.

The new regulations, which took effect in January 2019, include the following provisions:

• Short-term plans are limited to three months in duration with no renewals allowed.
• Insurers are prevented from selling short-term plans to an applicant who had already had three months of short-term coverage in the prior 12 months.
• Short-term plans are required to cover a list of basic inpatient, outpatient, and surgical services.
• Short-term plans must continue coverage (with no additional premiums) if the insured is hospitalized on the date that the short-term plan would otherwise have ended. The extension of coverage would last until the patient is discharged from the hospital.
• The lookback period for pre-existing conditions is limited to no more than 24 months (i.e., a pre-existing condition that hadn’t had symptoms or treatment for more than 24 months cannot be excluded).
• A short-term insurer must offer at least one plan with a per-person deductible of $2,000 or lower.
• The sale of short-term plans is banned during the open enrollment window that applies to ACA-compliant plans, if the short-term coverage is to take effect in January or February. So short-term plans can’t be sold in direct competition with ACA-compliant plans during open enrollment. State regulators noted that this is to help avoid confusion for consumers, since short-term plans purchased during open enrollment would take effect before the start of the new year, whereas ACA-compliant plans sold during open enrollment would take effect January 1 of the coming year (open enrollment for ACA-compliant plans in the individual market now runs from November 1 to January 15, and Washington’s rules have been updated to align with this).

As noted above, there were short-term plans available in the state until mid-2022. But since then, there have not been any short-term plans available.