Agent Answers

Selling ACA Plans Year-Round – Special Enrollment Periods and Positioning for OEP Growth in 2022

Written on November 10th, 2021

2021 has been a banner year for individual/family health insurance, with substantial increases in premium subsidies and record-high marketplace enrollment.

And 2022 looks promising as well, with most of the subsidy enhancements remaining in place, opportunities for low-income applicants to enroll throughout the year, and an influx of new insurers joining the marketplaces. Health insurance agents and brokers who understand these developments can position themselves for another successful year.

Before we dive into 2022, let’s take a brief look back at 2021.

2021 ACA Enrollment and American Rescue Plan – Quick Review

During the open enrollment period (OEP) for 2021 coverage, enrollment in marketplace plans grew to more than 12 million people[1], up from 11.4 million the year before.[2]

And enrollments grew again during the COVID-related special enrollment period that was available for much of 2021, driven in large part by the subsidy boosts provided by the American Rescue Plan (ARP).

More than 2.8 million people enrolled during the COVID-related special enrollment periods, pushing total effectuated marketplace enrollment to a record high 12.2 million people as of September 2021.[3]

More than two million of those 2.8 million enrollees were in states that use the federally-facilitated marketplace (FFM). During the same time frame (mid-February to mid-August) in 2019, only about 554,000 people enrolled in health plans through the FFM. Enrollment did increase during that time frame in 2020 — likely due to pandemic-related job losses — with about 752,000 people enrolling through the FFM between mid-February and mid-August. But the combination of the extended special enrollment period in 2021 and the larger premium subsidies resulted in dramatically higher enrollment numbers.[4]

And the ARP’s subsidy enhancements have made coverage much more affordable than it was in prior years. For example:

Biden Administration’s Focus on Supporting the ACA

One of President Biden’s campaign promises was to strengthen and build upon the ACA. The week after he took office, Biden signed an executive order designed to do just that.[5]

The Biden administration and Congress have taken various steps in 2021 to strengthen the ACA and fulfill its promise of affordable coverage. The American Rescue Plan has substantially boosted affordability, and the lengthy special enrollment period — which lasted at least six months in most states and is still ongoing in a few — gave people a chance to take advantage of the extra subsidies mid-year.

Looking Ahead to 2022: Affordable Plans, Additional Insurers and Regulatory Changes to Support the ACA-Compliant Market

For brokers who work in the ACA-compliant individual/family market, 2022 is shaping up to be a very promising year — in terms of sales as well as being able to give clients good news about premiums, enrollment opportunities, and plan availability.

Longer Open Enrollment Window for 2022 Coverage

In nearly every state, open enrollment for 2022 coverage will run through at least January 15, 2022. This is a month longer than open enrollment has been in most states for the last several years, and it’s a result of a rule change that the Biden administration finalized in September.[6]

The longer enrollment window will give consumers and brokers more time to compare plan options and select coverage for 2022. But in most states, applications will still have to be completed by December 15 in order to have coverage take effect January 1.

The extra month at the end of the enrollment window will be a good time to catch up with clients and potential clients whose holiday season was too busy to focus on health insurance. And it will also give people an opportunity to pick a new plan if they relied on auto-renewal and aren’t happy with plan or premium changes that take effect January 1.

Subsidy Boosts Remain in Place for 2022

The affordability boosts that the ARP made to the ACA’s subsidy structure will remain in place for 2022. That means that the percentage of income that people have to pay for the benchmark (second-lowest-cost silver) plan is lower than it was during last fall’s open enrollment period.

As has been the case in previous years, the percentage of income that an applicant has to pay for the benchmark plan will depend on household income (an ACA-specific calculation). But the percentage of income that people have to pay has been reduced.

Brokers who worked with clients during the special enrollment period in 2021 are already familiar with these affordability enhancements, but consumers who haven’t shopped for coverage in 2021 might be pleasantly surprised by how affordable coverage will be for 2022.

These percentages are normally indexed each year, but Section 9661 the ARP set them at these levels for 2021 and 2022.[7]

For reference, the 2021 poverty levels will be used to determine subsidy eligibility for all plans with 2022 effective dates.

Additional Insurers Joining the Marketplaces in Many States

For the fourth year in a row, additional insurers are joining the marketplaces in many states this fall. In some cases, these are new insurers that haven’t participated before, while others are insurers that exited the marketplaces in 2017 or 2018, and are returning now that the ACA-compliant individual/family market has shown several years of stability and profitability.

Consumers may find that the additional insurers present new options from which to select, or they may find that a new insurer takes over the benchmark spot and thus has an effect on subsidy amounts in the area. Either way, they’re likely to have questions for brokers, who will want to familiarize themselves with any new plans that will be available for 2022.

COBRA subsidies expired at the end of September

The American Rescue Plan provided a temporary full government subsidy for COBRA or state continuation, for workers who lost their jobs or had their hours involuntarily reduced. But that subsidy ended on September 30, 2021.[8]

At that point, people had a choice to switch to a marketplace plan, with marketplace subsidies if they were eligible. But assuming they had not yet exhausted their COBRA, they also had an option to keep it in place, paying the full price themselves.

People who had already spent a considerable amount in out-of-pocket costs for 2021 may have opted to pay full price to keep COBRA for the rest of 2021, to avoid starting over with a new deductible and out-of-pocket maximum in the final quarter of the year. But some of these people — especially those who may be eligible for substantial subsidies — may be better served by a marketplace plan for 2022, if their deductibles are resetting in January anyway.

There’s a 60-day special enrollment period (SEP) after a COBRA subsidy expires, during which a person can switch to a marketplace plan.[9]But people who want to switch to a marketplace plan as of January 1 can simply use the annual open enrollment period to select a new plan.

Elevated SEP Enrollments Likely to Continue in 2022

Many people think that ACA season ends when OEP ends. But according to Barb Moore, Manager of Broker Relations for INSXCloud, that isn’t entirely true. Moore indicates that “during 2020 we saw 45% of our enrollments come outside of OEP, many agents are active the entire year.”

These SEP sign ups have been higher than usual in recent years, due to the COVID pandemic. And 2022 is also likely to have elevated SEP enrollments, due to a new enrollment opportunity for lower-income applicants, as well as coverage transitions from Medicaid to marketplace plans once the COVID public health emergency ends.

Low-Income Enrollees Have a Monthly Enrollment Opportunity Throughout 2022

Because applicants with income up to 150% of the poverty level will be able to enroll in zero-premium benchmark plans in 2022, a rule change has been finalized to create a SEP that will allow these enrollees to sign up at any time throughout the year.[10]

This monthly enrollment opportunity will be available in all states that use, although it will be optional for state-run marketplaces.

Medicaid Eligibility Redeterminations After the COVID Emergency Ends

In addition to the new SEP for lower-income enrollees, the expectation is that millions of people could shift away from Medicaid in 2022. And many of them will be eligible to enroll in subsidized marketplace coverage instead.

Since March 2020, states have not been allowed to terminate Medicaid coverage (unless an enrollee requests it or moves out of state) or redetermine Medicaid enrollees’ eligibility. That will end once the public health emergency ends, and the expectation is that millions of people could lose their Medicaid coverage once routine eligibility redeterminations resume.[11]

Some of these individuals will be eligible to switch to employer-sponsored coverage. But for those who aren’t, brokers can provide assistance with the process of transitioning from Medicaid to a marketplace plan.

Employers Offering Individual Coverage Health Reimbursement Arrangements (ICHRAs)

ICHRAs are growing in popularity as a way for employers to provide benefits for their employees. ICHRAs use tax advantaged contributions from employers to help employees pay for their individual ACA plans.

ICHRAs are expected to become more popular in the coming years. A 2021 analysis by KFF and the Purchaser Business Group on Health found that 87% of employers are at least moderately likely to consider ICHRAs as a means of controlling costs, and nearly half are very likely to consider ICHRAs.[12]

If an employer starts offering an ICHRA that coincides with the calendar year, employees can simply use the fall open enrollment period to select an individual/family plan. But if an employer starts offering an ICHRA mid-year, the employees qualify for a SEP at that point, during which they can select an individual/family plan to use with the ICHRA.

Extended Deadlines for Individual SEPs Due to COVID-19 National Emergency

Typically, a person has 60 days from the time of their qualifying event to leverage their SEP and enroll in an ACA plan.

However, due to the FEMA declared national emergency, a person that has qualified for a special enrollment period as a result of losing qualifying coverage at any point since January 1, 2020 may be eligible for a SEP to obtain coverage for the rest of 2021, even if they’ve missed the standard 60-day window.[13]

Not sure if a client qualifies for an ACA special enrollment period? Use the SEP screener tool on

How to Prepare to Sell ACA Plans During 2022

As we’ve discussed, there are a number of reasons to think that ACA enrollment prospects in 2022 are good, including during the open enrollment period that runs through January 15, 2022, as well as individual special enrollment periods throughout the year.

Agents and advisors can use the time before, during, and after the OEP to grow their client base and help more people — and earn more money. Here’s how.

Step 1: Get Federally Facilitated Marketplace (FFM)-certified now

The course to become certified can be done at your own pace, and typically doesn’t take more than a couple of hours to complete.

CMS provides a free certification course so you can become eligible to quote and enroll people in on-exchange individual ACA plans.

If you’re already certified for 2021, you can recertify for plan year 2022 via a shorter refresher course that CMS also provides.

Step 2: Review enrollment platforms

Some agents choose to enroll on, but that isn’t your only option. The INSXCloud multi-carrier broker portal allows you to quote and enroll all individual ACA plans available in the 33 FFM states for 2022, and also provides quoting and enrollment for short term medical plans as well as accident, critical illness and dental plans.

Learn more about the versatility and convenience of INSXCloud or get signed up today to get started (it’s free to sign up and there’s no ongoing subscription fee).

Step 3: Understand and Contract with New Insurers

Insurance companies have been entering the ACA Marketplace since 2018, when the average number of Marketplace insurers per state was 3.5. In 2021 the average is five, with 20 states adding at least one insurer to their marketplace for 2021, including established brands like Friday Health, Oscar Health, and Bright Health.[14]

And as noted above, the trend of increasing insurer participation is continuing for 2022, with several big-name insurers joining or rejoining the marketplaces, along with numerous regional insurers.

Positioning yourself as an agent who can offer choice and plan fit may put you in a position to win more sales and help more people get the right coverage. So you’ll want to be sure you’re familiar with any new plans that are rolling out in your area, and are contracted with all of the available insurers.

If you’re already contracted with IHC Specialty Benefits and want to learn more about the carriers offered through your Independence Brokerage Group (IBG) relationship please contact your IHC representative.

Not contracted with IHC Specialty Benefits and want to learn more about our carriers? Contact us today and let us know how we can help, or start the process to get contracted.

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Summary + Next Steps

The open enrollment period in the fall of 2021 is a great opportunity to introduce your clients to the improved affordability provisions in the marketplace; they may be pleasantly surprised by the plans and prices you can offer them!

You’ll have until at least January 15, in most states, to complete enrollments for 2022. And even after the open enrollment period ends, there will continue to be widespread opportunities to help people enroll in ACA-compliant health plans throughout 2022.

Get started today by getting certified to sell ACA plans and signing up for the INSXCloud multi-carrier quote and enrollment portal.


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  • [1] Centers for Medicare and Medicaid Services. 2021 Marketplace Open Enrollment Period Public Use Files.
  • [2] Centers for Medicare and Medicaid Services. 2020 Marketplace Open Enrollment Public Use Files.
  • [3] Centers for Medicare and Medicaid Services. Biden-Harris Administration Announces Record-Breaking 12.2 Million People Are Enrolled in Coverage Through the Health Care Marketplaces. September 15, 2021.
  • [4] Centers for Medicare and Medicaid Services. 2021 Final Marketplace Special Enrollment Period Report. September 2021.
  • [5] Biden, Joe. The White House. Executive Order on Strengthening Medicaid and the Affordable Care Act. January 28, 2021.
  • [6] U.S. Department of the Treasury, and Department of Health and Human Services. Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond. September 17, 2021.
  • [7] H.R.1319 — American Rescue Plan Act of 2021 (Section 9661). Enacted March 11, 2021.
  • [8] Department of Labor. FAQs About COBRA Premium Assistance Under the American Rescue Plan Act of 2021. April 7, 2021.
  • [9] U.S. Department of Health and Human Services; Centers for Medicare and Medicaid Services. Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards. May 5, 2021.
  • [10] U.S. Department of the Treasury, and Department of Health and Human Services. Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving Health Insurance Markets for 2022 and Beyond. September 17, 2021.
  • [11] Serafi, Kindra; Mann, Cindy; Punukollu, Nina V. The Commonwealth Fund. The Risk of Coverage Loss for Medicaid Beneficiaries as the COVID-19 Public Health Emergency Ends. September 23, 2021.
  • [12] Claxton, Gary; Levitt, Larry; Rae, Matthew (KFF); Kramer, William; Gremminger, Shawn (Purchaser Business Group on Health). How Corporate Executives View Rising Health Care Costs and the Role of Government. April 2021.
  • [13] Enroll in or change 2021 plans — only with a Special Enrollment Period.
  • [14] McDermott, Daniel; Cox, Cynthia. KFF. Insurer Participation on the ACA Marketplaces, 2014-2021. November 23, 2020.