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Short-Term Health Insurance Soon Available For Up To 36 Months

New Rule Loosens Current Restrictions

Effective October 2, 2018, a new rule will allow individuals to purchase short-term, limited-duration health insurance coverage for a period of less than 12 months, and renew such coverage for up to 36 months. Under current law, the maximum coverage period for short-term, limited-duration health insurance is less than 3 months, and these policies cannot be renewed.

Notably, short-term, limited-duration health insurance is:

  • Not required to comply with the Affordable Care Act’s ban on pre-existing condition exclusions and lifetime and annual dollar limits.
  • Not required to comply with the Affordable Care Act’s essential health benefits requirement, which requires individual health insurance policies to cover, among other things, hospitalizations, emergency services, and maternity care.
  • Not “minimum essential coverage,” meaning that policyholders may remain liable for an individual mandate penalty for any month in 2018.

Click here to read the new rule. A fact sheet is also available.

person signing up for health insurance on tablet

Current Requirements Continue to Apply Until Proposal is Finalized

Federal agencies recently proposed to amend the definition of short-term, limited-duration insurance so that it may offer a maximum coverage period of less than 12 months after the original effective date of the contract, rather than the current maximum period of less than 3 months. The proposal would also revise the required issuer notice that must be displayed in the contract and any application materials.

Proposal Applicability Date

While the current definition applies to policy years beginning on or after January 1, 2017, a non-enforcement policy applies to policies sold before April 1, 2017, and that end on or before December 31, 2017. The current definition and non-enforcement policy would continue to apply unless and until the proposal is finalized. If finalized, the proposal would apply to insurance policies sold on or after the 60th day following publication of the final rule. Policies sold on or after this date would have to meet the definition of short-term, limited-duration insurance in the final rule in order to be considered such insurance.


Under the Affordable Care Act, short-term, limited-duration insurance is exempt from certain market reforms. The allowable duration of such insurance is currently limited to less than 3 months after the original effective date of the contract. In addition, this insurance is not considered minimum essential coverage, which is necessary for an individual to satisfy the individual mandate unless an exemption applies.

Click here to read the proposal in its entirety. A fact sheet is also available.