March 31 was the last day to enroll in a health insurance plan through the federally-facilitated health care exchange. However, like many other Affordable Care Act (“ACA”) deadlines, the March deadline was a soft deadline, as certain consumers may receive additional time to enroll in a health insurance plan. The Centers for Medicare and Medicaid Services (“CMS”) recently released guidance pertaining to possible extended enrollment periods for consumers. The releases, titled “Guidance for Issuers on Special Enrollment Periods for Complex Cases in the Federally-Facilitated Marketplace after the Initial Open Enrollment Period” (the “SEP Guidance”) and “Guidance for Issuers on People ‘In Line’ for the Federally-Facilitated Marketplace at the End of the Initial Open Enrollment Period” (“In Line Guidance”), outline “special enrollment periods” after the March 31 deadline for some consumers and grant relief for those consumers who were “in line” on the exchange website, HealthCare.gov, but were unable to enroll due to high volume, respectively. The deadline to enroll for those who were “in line” on HealthCare.gov is now April 15, 2014.
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