Dec. 23 Deadline Extended One Day; Key Deadline for Purposes of the Mandate is March 31

December 24, 2013, is a key date for health care reform across the U.S.  Thanks to a one-day extension, announced today, midnight on December 24^th is now the deadline for signing up for coverage in the federal health insurance marketplace in order to have coverage on January 1.  However, people have a little longer to pay for their first month of private health insurance obtained through the Marketplace, and the current open enrollment period for signing up for that coverage runs until the end of March.

There has been confusion about some of the key dates, resulting from recent policy changes at both the federal and state level and from some misstatements about the federal law.  One area of confusion relates to the deadline for obtaining coverage and complying with the mandate in the Affordable Care Act (ACA) that most people must have health insurance in 2014 (or pay a penalty).  For example, Dan Schwartzer, Wisconsin’s Deputy Insurance Commissioner, recently implied – incorrectly – that federal penalties would be assessed for people who don’t get insurance by January.  According to this December 11^th story on Wisconsin Public Radio, Schwartzer said: “If someone made every attempt by Dec. 23 to get coverage and they weren’t able to get coverage … it’s hard to enforce that penalty on that individual if in fact they made every attempt and they still couldn’t get in.”

The implication of that statement was that the key date for purposes of complying with the individual mandate is January 1, 2014.  However, that’s not the case because there is no penalty for a gap in coverage of three months or less.

A new WCCF paper summarizes the individual mandate and explains the key dates over the next few months.  Here are some of the most important of those dates:

• December 24^th, 2013: Last day to enroll in a Qualified Health Plan on the Marketplace in order to have coverage begin on January 1^st
• December 31^st, 2013: Last day to pay the first month’s premium for Marketplace coverage to begin on January 1^st – for coverage by insurers who aren’t members of America’s Health Insurance Plans (AHIP).
• January 1^st, 2014: The first possible day of Marketplace coverage; people who have minimum essential coverage by this day and maintain it throughout the year (or have no less than a 3-month coverage gap) will not face a penalty
• January 10^th, 2014: Last day to pay the first month’s premium for Marketplace coverage to be retroactively granted beginning on January 1^st (for AHIP-member insurers)
• February 3^rd, 2014: Childless Adults below 100% FPL can begin applying for BadgerCare coverage using the Marketplace application or ACCESS.wi.gov for BadgerCare Plus coverage that begins on April 1, 2014.
• March 15^th, 2014: Last day that those losing BadgerCare Coverage can apply for insurance through the Marketplace in order to avoid an insurance gap when their BadgerCare coverage ends on March 31^st
• March 31^st, 2014: Last day to enroll in a Qualified Health Plan on the Marketplace in order to avoid the penalty for more than 3 months of the year without insurance
• April 1^st, 2014: Effective date of changes to BadgerCare, and date by which people need to have coverage (unless they enrolled in Marketplace coverage between March 16^th and 31^st) in order to avoid to avoid paying a tax penalty for not having coverage.

See the new WCCF paper to read more about the individual mandate, including a list of the various exemptions.

Jon Peacock