Evaluating special enrollment periods and change effective dates

Greetings from Maryland Health Benefit Exchange (MHBE) and many thanks to everyone who has been working hard to keep Marylanders covered, while adapting to rapidly changing circumstances in both your home and work lives. Much of the activity in Maryland Health Connection (MHC) now, and likely in the coming weeks and months, will be centered on households who have experienced a job loss, an income change, a loss of employer-sponsored health coverage, or all the above. These changes may be followed by new opportunities to enroll in coverage through the marketplace or changes in existing coverage to make it more affordable for new budgets.

The careful consumer assistance worker will want to evaluate the consumer’s circumstances to match the Special Enrollment Period (SEP) selection with an enrollment effective date best suited to the household’s needs. Particularly for Qualified Health Plan (QHP) coverage, a household could be eligible for more than one type of SEP or for a change in program or benefits for more than one reason. In these cases, the determinative factor for choosing might be the effective date.

Type of change	Effective date
Loss of Minimum Essential Coverage (MEC) reported before loss	1st of the month after loss
Loss of MEC reported after loss	1st of the month following plan selection
Maryland Easy Enrollment Health Insurance Program	1st of the month following plan selection
COVID-19	1st of the month following plan selection

Plan selected	Effective date
4/16-5/15	5/1
5/16-6/15	6/1
Individual coverage + loss of income	15th of the month rule
QHP churning to Medicaid	1st of the month of Medicaid eligibility
Enrolled with change in Advanced Premium Tax Credit (APTC)	1st of the following month
Enrolled with complete loss or gain of APTC	15th of the month rule

Note: Loss of job alone is not a qualifying life event for an SEP.

Young adults

Up to age 26, a child can be enrolled (or re-enrolled) on parents’ plan if the adult child can no longer afford their own coverage due to job loss, even if they’re not a tax dependent and even if they’re married.

If you have any questions about SEPs and enrollment effective dates, please contact Director of Consumer Assistance, Eligibility & Business Integration Heather Forsyth: heather.forsyth@maryland.gov.