CMS has extended the Affordable Care Act (ACA) insurance enrollment period for individuals (1) who have had difficulty signing up for a health insurance plan through an Affordable Insurance Exchange by March 31, 2014, or (2) who have not signed up by March 31 due to a wide range of circumstances. First, in a March 26, 2014 document, CMS announces it has established a “special enrollment period” for individuals who cannot complete the enrollment process “despite their best efforts” for reasons such as “high consumer traffic across various consumer enrollment channels…leading up to the March 31 deadline.” Provided that consumers who were “in line” pay their first month’s premium by the deadline set by their chosen insurance company, CMS anticipates that enrollments made in an unspecified time period after March 31 will have a May 1 coverage effective date. Consumers who receive a special enrollment period for being “in line” and select new coverage within the timeframes outlined in the guidance will be able to claim a hardship exemption from the shared responsibility payment for the months prior to the effective date of their coverage.

CMS also has compiled all of the categories CMS has identified to date that warrant special enrollment periods after the end of the March 31 open enrollment period, including situations involving: certain exceptional circumstances; misinformation, misrepresentation, or inaction by entities providing formal enrollment assistance; enrollment error; system errors related to immigration status; display errors on Marketplace website; Medicaid/CHIP – Marketplace transfer problems; error messages; unresolved casework; victims of domestic abuse; or other system errors that hindered enrollment completion.