A new job is not a qualifying event for a SEP

Now that open enrollment is over, the only way people can enroll in individual health plans is with a qualifying event.  This applies both on and off the exchange. Outside of open enrollment, individual/family health insurance is only for sale if you’ve got a special enrollment period triggered by a qualifying event.

So what constitutes a qualifying event?  I’ve explained it in detail here, including updates for 2015.  Here is the healthcare.gov page about qualifying events. There’s a long list of qualifying events and corresponding special enrollment periods, most of which apply both on and off the exchange (there are some qualifying events that only apply in the exchange).

But there’s some general confusion when it comes to getting a new job.  A month ago, Healthcare.gov tweeted that “A new job new job is not a qualifying eventqualifies you for a Special Enrollment Period.”  I replied to that tweet, pointing out that a new job in and of itself IS NOT a qualifying event, and does not trigger a special enrollment period.

Healthcare.gov never replied to my tweet, but a couple weeks later, they posted a similar tweet, but changed the wording slightly, to “Got a new job? That might qualify you for an SEP.

Obviously, Colorado isn’t using Healthcare.gov, as Connect for Health Colorado is a state-run exchange.  But in both the Colorado exchange and the federal exchange (and off-exchange too), getting a new job is NOT a qualifying event for a SEP.

There are a few qualifying events that are probably being conflated here, because they’re often associated with getting a new job:

  • First, loss of coverage IS a qualifying event.  So if you leave a job and lose your health insurance coverage, you’re eligible for a special enrollment period.  You might also be starting a new job in the same time frame, but that’s not the reason you’ve got a special enrollment period.
  • Another possibility could be a permanent move that triggers a qualifying event.  If you get a new job and move to a new area (where there are different health plans available), you’re eligible for a special enrollment period.  But again, this isn’t triggered by the new job, it’s triggered by the fact that you’ve moved to a new area.  If you get a new job but you don’t need to move to take it, there’s no special enrollment period.
  • The other qualifying event – which actually doesn’t apply in Colorado but could be part of the reason for the Healthcare.gov tweets – applies to people in the coverage gap in states that haven’t expanded Medicaid.  Although a change in income is not normally a qualifying event, the coverage gap presents a unique challenge.  In states that haven’t expanded Medicaid, people with incomes below the poverty level are not eligible for any health insurance assistance at all.  They don’t get Medicaid unless they qualify under the state’s existing rules (which in most cases don’t allow for any Medicaid coverage at all for childless adults, regardless of how low their income is), and they also don’t qualify for subsidies in the exchange.  So HHS created a qualifying event rule for individuals in that situation whose income increases during the year to put them over the poverty level and thus make them eligible for subsidies in the exchange.  Thus, if they get a new job and therefore have an increase in income that’s enough to make them eligible for subsidies, they’re allowed to enroll at that point.  But again, this doesn’t apply in Colorado or any other state where Medicaid has been expanded.

So to clarify, getting a new job is not a qualifying event, and does not trigger a special enrollment period in the individual market.  Obviously, it does trigger a special enrollment period for the group coverage at the new job, if the employer offers coverage.  But it’s not a qualifying event in the individual market, on or off the exchange.

About Louise Norris

Louise Norris has been writing about health insurance and healthcare reform since 2006. In addition to the Colorado Health Insurance Insider, she also writes for healthinsurance.org, medicareresources.org, Verywell, Spark by ADP, and Boost by ADP, and Gusto. Follow on twitter and facebook.

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