In a typical January, brokers handling ACA enrollment receive a predictable set of calls from clients who found out they needed health insurance on January 20th. By then, the Healthcare.gov January 15 deadline has passed. Most of those calls produce one of two outcomes: the broker finds a qualifying event from the past 60 days that opens an SEP, or the broker explains the alternatives to an uninsured client until November.
Key Takeaways
- Healthcare.gov open enrollment closes January 15. Applications submitted after January 15 without a documented special enrollment period (SEP) qualifying event are rejected. The next enrollment window opens November 1.
- Medicaid is year-round coverage with no enrollment window. In the 41 states (including DC) that expanded Medicaid under the ACA, a single adult earning up to 133 percent of FPL — approximately $20,783 in 2026 — qualifies. CHIP covers children in families above that threshold.
- A client who experienced a qualifying life event — job loss, divorce, birth, adoption, change of residence, or loss of other coverage — between 60 days ago and today likely has an active SEP. Digging into the past 60 days before accepting 'no SEP' is worth five minutes.
- Short-term health plans are not ACA-compliant coverage and expose clients to financial risk on pre-existing conditions. CMS requires specific written disclosures before a broker sells a short-term plan. The plan duration and renewal limits are set by state and federal regulation and have changed multiple times since 2018.
- Some state-based exchanges have special enrollment provisions that differ from Healthcare.gov. California, Connecticut, and New York have had periods of expanded enrollment access. Check the current rules for the client's state-based exchange before telling them no options exist.
The January 15 deadline and what happens after it
Healthcare.gov open enrollment runs November 1 through January 15. An application submitted through Healthcare.gov after January 15 without a valid special enrollment period code will be denied. The federal Marketplace does not have a grace period or a late application review process for standard OEP applications after the deadline. State-based exchanges set their own deadlines, which in some years differ from January 15.
The next ACA Marketplace enrollment opportunity opens November 1 for coverage beginning January 1 of the following year. For a client who misses the January 15 deadline in 2027, the earliest ACA plan effective date is January 1, 2028, unless they acquire a qualifying event in the interim.
Before accepting that conclusion, work through the 60-day lookback. The most common missed qualifying event is involuntary loss of coverage that the client did not initially recognize as a qualifying event. A client who was dropped from a spouse's employer plan during the employer's own open enrollment process in November — without going through the ACA OEP themselves — has a 60-day SEP window from the date of that coverage loss. If that date was December 20, the SEP window is still open through February 18.
Medicaid: the year-round path most brokers underuse
Medicaid has no annual enrollment window. Any person who meets their state's Medicaid eligibility criteria can apply and receive coverage at any point in the year. In the 41 states (plus DC) that expanded Medicaid under the ACA, a single adult with annual household income at or below approximately 133 percent of the federal poverty level qualifies as of 2026. With the standard 5 percent income disregard, the effective threshold for a single adult is approximately $20,783.
A client who earns $18,000 per year has no coverage gap in January. They qualify for Medicaid today and can apply through their state's Medicaid office or through Healthcare.gov (which screens and routes Medicaid applicants). The application to coverage timeline is typically 45 days from submission. Some states provide faster determinations.
The non-obvious angle here: a client who loses Medicaid eligibility due to an income change gets a 60-day SEP to enroll in a Marketplace plan. That means a client who receives Medicaid now, gets a job in March that puts them over the Medicaid threshold, and loses Medicaid in May has a 60-day window to enroll in an ACA Marketplace plan for June 1 coverage — regardless of where we are in the calendar.
| Coverage option | Who qualifies | Year-round? | ACA-compliant MEC? |
|---|---|---|---|
| Medicaid (expansion states) | Up to ~133% FPL (~$20,783/single in 2026) | Yes | Yes — MEC |
| CHIP | Children in families above Medicaid threshold | Yes | Yes — MEC |
| Basic Health Program (NY, MN, OR) | 133 to 200% FPL in participating states | Generally yes | Yes — MEC |
| Employer group plan | Employed; employer offers coverage | Employer OEP schedule | Yes — MEC (if MVC meets ACA standards) |
| Short-term health plan | Most states; health questions required | Yes | No — not MEC |
| COBRA continuation | Lost employer coverage within past 60 days | Yes, within election window | Yes — MEC |
| Next ACA OEP | All Marketplace-eligible applicants | Opens November 1 | Yes — MEC |
Illustrative summary. Eligibility thresholds reflect 2026 FPL guidelines. State-specific rules apply. Confirm Medicaid income limits with your state Medicaid agency before counseling a client.
COBRA: the option that already has a 60-day clock running
A client who lost employer coverage within the past 60 days has not actually missed the ACA deadline — they have an active SEP for loss of minimum essential coverage. COBRA is also available as an alternative within the 60-day election window, but COBRA's cost (the full premium plus up to 2 percent administration) is often higher than a subsidized Marketplace plan.
The practical broker move: run the APTC estimate before recommending COBRA to any client with income below 400 percent of FPL. A client earning $42,000 a year as a single adult who lost their employer plan in November may be paying $600 per month for COBRA when a subsidized Silver plan would cost $80 per month. QualityQuotes's plan finder runs that comparison in about 90 seconds using live CMS Marketplace data.
Short-term plans: when to present them and what the disclosures require
Short-term health plans exist in most states and are available year-round with no enrollment window. They are sold through standard broker channels. They are not ACA minimum essential coverage and should not be presented as equivalent to a Marketplace plan.
The non-obvious point for brokers: selling a short-term plan to a client with a pre-existing condition is not just a coverage gap problem for the client — it is a documentation problem for the broker. The client who buys a short-term plan for a kidney condition that was diagnosed three months ago and then has a related claim denied has a clear paper trail back to the broker who recommended the plan. The required disclosures must be delivered in writing, not verbally, and retained.
Federal and state rules on short-term plan duration and renewability have changed multiple times since 2018. Before placing any short-term plan, confirm current allowable duration in the client's state. Some states prohibit short-term plans entirely. Others cap the initial period at three or four months, with or without renewal rights.
State-based exchange alternatives: the year-round provisions worth knowing by state
Not all states use Healthcare.gov. In the states that run their own exchanges, the enrollment rules differ. California (Covered California) historically maintained an enrollment calendar similar to Healthcare.gov. New York, Connecticut, and Massachusetts have had periods of expanded enrollment access during public health emergencies.
New York and Minnesota operate Basic Health Programs — state-run coverage for adults at 133 to 200 percent of FPL that runs outside the standard ACA OEP timeline and is generally accessible year-round. A client in New York who earns $28,000 a year and missed the OEP deadline is not without options: the Essential Plan (New York's BHP) accepts applications continuously.
For the exceptional circumstances SEP category, a broker should check whether CMS or a state exchange has issued any active declarations. Natural disasters, state-declared emergencies, and confirmed system errors can all support an exceptional circumstances SEP claim. These declarations are time-limited and posted to CMS.gov.
What to document for a client who ends up uninsured until November
A client who has no viable alternative path to coverage until November needs a plan for that period. Document the conversation: that you reviewed Medicaid eligibility, CHIP eligibility, any employer coverage options, state-specific alternatives, and any qualifying events from the past 60 days. Note the result of each check.
Then start the November 1 calendar. Pre-schedule the next ACA enrollment conversation for the third week of October. That call will include an income update, a look at any life changes during the year, and the new plan-year premium calculations once CMS releases plan data. Clients who miss one OEP window and receive a structured plan for the next one tend to enroll on time.
Missed ACA open enrollment: direct answers
What CMS rules say and what brokers can do in practice.
Is there any way to get an ACA plan after January 15 without an SEP?
No, unless the client lives in a state whose state-based exchange has an active extended enrollment provision. On Healthcare.gov, the rule is firm: after January 15 without a documented qualifying life event, a new enrollment application will not be accepted until the following November 1 open enrollment period opens. The one exception that sometimes applies is the 'exceptional circumstances' SEP category, which CMS has used to extend access for natural disasters, system outages, and other situations outside the client's control. A broker whose client missed the deadline due to a documented system error or declared disaster should contact the Marketplace directly about an exceptional circumstances request.
Does Medicaid really accept applications any time of year?
Yes. Medicaid has no enrollment window equivalent to the ACA OEP. Any person who meets their state's Medicaid eligibility requirements can apply and receive coverage starting approximately the first day of the month following approval, or potentially retroactively in some states. The 41 states (including DC) that expanded Medicaid under the ACA extended eligibility to adults earning up to 133 percent of FPL (138 percent with the 5 percent income disregard). For 2026, that threshold is approximately $20,783 for a single adult. A client who earned too much for Medicaid during open enrollment may now qualify if their income dropped. Eligibility is based on current projected annual income, not prior-year income.
What SEP categories should a broker check before saying the client has no option?
The most commonly missed SEPs are: loss of minimum essential coverage within the past 60 days (including the end of COBRA, Medicaid termination, or aging off a parent's plan); a permanent change of primary residence to a new rating area within the past 60 days; marriage or divorce within the past 60 days; birth, adoption, or foster care placement within the past 60 days; and gaining or losing status as a dependent. Income changes are not themselves a qualifying event, but they may make a client newly eligible for Medicaid (year-round) or change their APTC. Run through the full 60-day lookback with the client before concluding no SEP applies. Brokers using Inshura or the federal enrollment platform should confirm which SEP codes are available in the system before selecting one, as documentation requirements differ by category.
What are the required disclosures before selling a short-term health plan?
Federal regulations and most state regulations require brokers to provide written notice to a client that a short-term health plan is not minimum essential coverage under the ACA, does not cover pre-existing conditions in most cases, is not required to cover the ACA essential health benefits, is not renewable in the way ACA plans are, and does not qualify the client for an ACA special enrollment period when the short-term plan ends. The exact disclosure language is set by federal and state rule, and the wording has changed as the underlying regulation has changed. Before selling any short-term plan, confirm that the disclosure form is current for the applicable state and plan year. Delivering the required disclosure verbally but not in writing creates documentation risk if the client later has a claim denied for a pre-existing condition.
What is the Basic Health Program and which states offer it?
The Basic Health Program (BHP) is a coverage option authorized by the ACA under Section 1331. It is a state-run program for individuals who earn 133 to 200 percent of FPL and would otherwise qualify for a subsidized Marketplace plan. As of 2026, Minnesota (MinnesotaCare) and New York (Essential Plan) operate BHPs. Oregon received CMS approval for a BHP starting in 2024. In BHP states, a client who earns between 133 and 200 percent of FPL is directed to the BHP rather than the Marketplace, and BHP enrollment is generally available year-round without an annual open enrollment window. For a client in New York or Minnesota who missed OEP and earns in the 133 to 200 percent FPL range, the BHP may provide a better coverage option than a short-term plan.
