Open Enrollment Ends on Different Days in Different States

What Open Enrollment actually is, right now

Every year, the ACA Marketplace holds a window called the annual Open Enrollment Period, when anyone can sign up for individual or family health coverage, or switch plans, without needing a qualifying life event. HealthCare.gov's own current guidance puts the 2027 coverage window at November 1, 2026 through January 15, 2027, with coverage starting January 1 for anyone who enrolls by December 15.¹ That is the number most agency sites, call scripts, and landing pages have been trained to repeat for years, because for most of the country it has been true.

It is not true everywhere. Thirty-some states and D.C. use HealthCare.gov as their Marketplace, but more than twenty states run their own exchange, and a state-run exchange sets its own Open Enrollment calendar.⁹ Georgia runs Georgia Access instead of HealthCare.gov, and happens to land on the same November 1 to January 15 window this year.⁷⁸ New Jersey's GetCoveredNJ and Covered California both run three months longer, through January 31, 2027.⁵⁶ Massachusetts Health Connector has run through January 23 in its recent cycles.⁹ None of that is a typo or a rounding error. It is the actual, current design of the program: one national start date, several different end dates, decided state by state.

That design goes back to how the ACA itself was built. The law gave states a choice: run your own exchange, or default to the federal one the government built for everyone who didn't. Most states took the default. A couple dozen didn't, and the ones that run their own have always had latitude to set their own enrollment calendar, their own plan certification rules, and their own consumer assistance programs. A hardcoded national Open Enrollment date was never fully accurate for the whole country. It was just close enough, for long enough, that nobody's website got caught being wrong about it. This year's litigation didn't create that gap. It just made the gap wider and more visible, by briefly threatening to close it entirely and then reopening it at the last minute.

It also matters more for a multi-state book than a single-state one, and it matters most of all for an FMO or IMO whose downline writes across a dozen states or more. A single agency licensed only in Ohio can get away with one hardcoded HealthCare.gov date on every page, because Ohio uses HealthCare.gov. An agency, or a network of agencies, writing business in Ohio, New Jersey, and California at the same time cannot, because one of those three sentences is simply false for two of the three states. The more states a book of business touches, the more a single shared template line turns from a convenience into a liability.

The rule that tried to make every date the same

The reason this got complicated for 2027 specifically traces back to a single federal rule. On June 25, 2025, CMS finalized the Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability Rule, published in the Federal Register at 90 FR 27,074.² Among a long list of changes to eligibility verification, special enrollment periods, and income redeterminations, the rule added a new limit on the length of the annual Open Enrollment Period itself, starting with benefit years beginning in 2027.²

The rule's own text is specific. It caps the Open Enrollment Period so that it "does not exceed 9 weeks" under 45 CFR 155.410(e)(5)(ii), and requires that for 2027 and later benefit years, the period "must begin no later than November 1 and end no later than December 31" of the preceding calendar year for any exchange that sets its own dates.² For exchanges running on the federal platform, meaning HealthCare.gov, the rule did not leave room for variation at all: it fixed "the dates of the OEP each year for Exchanges operating on the Federal platform" at November 1 through December 15.² That is a full month shorter than the January 15 close HealthCare.gov is actually using for 2027 right now, which is the first clue that the rule, as written, is not the rule currently in effect.

CMS framed the rule as part of a broader package meant to tighten eligibility verification and curb improper enrollments, alongside a pause on the low-income special enrollment period and changes to how exchanges verify income.² Shortening and standardizing the enrollment window was presented as one piece of that integrity push, not an isolated change. It mattered to agencies for a narrower reason: a shorter, uniform calendar is simple to write once into a template and never think about again. That is exactly the version of 2027 that did not end up shipping.

How a Maryland court undid it, for now

The rule did not go unchallenged. On July 1, 2025, the cities of Columbus, Chicago, and Baltimore, joined by Doctors for America and the Main Street Alliance, sued HHS, CMS, and their administrators in the U.S. District Court for the District of Maryland, in a case captioned City of Columbus v. Kennedy, No. 1:25-cv-02114, arguing the rule was unlawful under the Administrative Procedure Act.³ Judge Brendan Abell Hurson had already paused parts of the rule on a preliminary basis in August 2025, before it even took effect.³

The case ran for nearly a year before it reached a final decision on the merits. On June 12, 2026, Judge Hurson issued a memorandum opinion and order granting the plaintiffs' motion for summary judgment in part and denying the government's cross-motion in part, vacating the challenged provisions of the rule "as specified herein," with a clarifying amendment entered June 16.³ Trade press coverage of the ruling, including Becker's Payer Issues, reported that the vacated provisions specifically included the rule's shortened, standardized Open Enrollment Period for 2027 coverage.⁴ HHS did not accept the loss quietly: it filed a notice of appeal to the U.S. Court of Appeals for the Fourth Circuit on July 16, 2026, and the appeal was docketed there as No. 26-1938 on July 21, 2026.³

A few of those legal terms are worth defining plainly, since they're doing real work in this story. Summary judgment is a court's ruling that the undisputed facts already decide the case, without needing a full trial, because no reasonable judge or jury could come out the other way on those facts. When a court vacates a rule, it is not merely pausing it, the way a preliminary injunction does while a case is still being argued. Vacatur sets the rule aside as if it were never validly issued, which is why HealthCare.gov's live page can simply revert to the longer, pre-rule calendar rather than waiting for some future effective date. An appeal to the Fourth Circuit doesn't undo that on its own. It asks a higher court to review whether the district court got the law right, and until that appellate court rules, the district court's vacatur stands.

A federal rule tried to put every exchange on one calendar. A federal court put most of them back on their own. The only thing both sides agree on right now is November 1.

The 2027 window, exchange by exchange

Here is what each exchange checked for this guide is actually telling consumers today, not what the vacated rule would have required. Confirm your own state's exchange directly before publishing a date, since this is exactly the kind of fact that can move again before January.

Two things are worth sitting with in that table. First, every single exchange opens on the same day. The variation is entirely on the back end, which means a date you see confidently stated as "Open Enrollment runs November 1 to [X]" is doing two different jobs: the November 1 half is safe to say for any audience, and the end-date half is not safe to say for any audience until you know which exchange that specific reader is shopping on. Second, more than one state kept a longer window than HealthCare.gov on purpose, not by accident. New Jersey's own regulator says so directly: "a recent court decision restored the ability for States to set longer Open Enrollment periods," and New Jersey "historically offered a three-month window" and chose to keep it.⁵ That is a state deliberately diverging from the federal platform's calendar, which is a detail a lot of national-template content never bothers to check for.

Why agency sites keep publishing one date anyway

None of this is because agencies don't care about getting it right. It's because the way most agency websites get built makes a single hardcoded date the path of least resistance, and nobody revisits it until something forces the issue.

A page builder platform or a page cloned from a competitor site tends to carry whatever Open Enrollment sentence was already sitting in the template when the page was copied. Nobody checks whether that sentence was written for HealthCare.gov, for a specific state exchange, or for a plan year that's already over. A seasonal landing page built fast for one AEP and OEP cycle, meant to be rebuilt next year, often just gets its year swapped and ships again, with the end date untouched because whoever updated it assumed the calendar doesn't change. And a multi-state agency that grew by adding licenses one state at a time usually started with a single home-state page, then copied it for every new state without re-checking the one line that doesn't travel: the deadline.

Put those three habits together and you get exactly what shows up in an audit: a site with a dozen state-specific landing pages that all carry the identical Open Enrollment sentence, because it was correct the one time, for the one state, that the sentence was first written.

None of this is a criticism of how those pages were built in the first place. A static date is a completely reasonable thing to write down when the underlying fact actually is static, and for most of the program's history, the Open Enrollment calendar changed rarely enough that treating it as fixed was a safe bet. What changed this year isn't that agencies got careless. It's that the fact underneath the sentence became unusually unstable, first because a rule tried to overwrite it nationally, then because a court overwrote the rule, with an appeal still pending that could overwrite it again. A sentence built to be typed once stops being safe exactly when the fact behind it stops holding still.

What could still change before January

None of this is settled law in the sense of being finished. The Fourth Circuit appeal docketed as No. 26-1938 was still open as of this guide's publication, with no decision issued.³ If the Fourth Circuit reverses the Maryland ruling, the nine-week cap and the December 15 HealthCare.gov close could come back into force, though CMS would need to work out timing for any plan year already underway when that happens. If the ruling is affirmed or the appeal is dismissed, the current state-by-state picture in the table above is likely to be closer to the durable baseline going forward.

There's a reason to take the appeal seriously rather than assume it fizzles out. The government didn't let its first appellate attempt in this case lapse by accident: when an earlier appeal was voluntarily dismissed so the case could finish at the district court first, HHS came back with a fresh notice of appeal within weeks of the June 12 ruling, and the Fourth Circuit opened the new case the following week.³ That's the posture of an agency still actively pursuing the rule as written, not one that's content to let the longer, state-set windows become the permanent status quo by default.

Either way, the practical lesson for an agency site is the same: this is not a fact you learn once and publish forever. It is a fact with an open court docket attached to it, which means the right way to handle it on a website is closer to how you'd handle a stock price than how you'd handle a ZIP code. A page that states the plan year and the date you last checked, like "Open Enrollment runs November 1, 2026 to January 15, 2027 on HealthCare.gov, current as of October 2026," survives a future change far better than a page that just says "Open Enrollment ends January 15" with nothing to tell a reader, or a crawler, how fresh that claim is.

What one hardcoded date actually costs you

Picture the sentence a lot of agency homepages and funnel pages carry: "Open Enrollment runs November 1 to January 15. Don't miss your window." If that agency writes business in New Jersey, California, or Massachusetts, that sentence is quietly telling some share of its own prospects that they have less time than they actually do, which is the kind of thing that either rushes a decision unnecessarily or, worse, convinces someone who still had weeks left that they already missed their shot.

There's also a citation angle here that matters beyond any one reader. When a prospect asks an AI assistant "when does Open Enrollment end in [state]," the assistant is looking for a source that answers the actual question asked, with the actual state named, not a generic national answer copy-pasted from HealthCare.gov. A page that only has room for one number, with no state attached, is giving an answer engine nothing it can confidently attribute to the right reader. An earlier guide on this blog covered how AI Overviews get a documented share of life insurance answers outright wrong; a vague or unstated-state date isn't a factual error in the same way, but it's the same category of problem, a claim that reads as precise while actually being underspecified for the question being asked.

Work through a concrete case. Say an FMO's downline writes ACA business across Ohio, New Jersey, and California, three states among the handful checked for this guide. A single shared "Open Enrollment ends January 15" banner, pushed to every downline agent's site at once, is accurate for the Ohio pages, wrong by sixteen days for the New Jersey pages, and wrong by sixteen days for the California pages too. That's two-thirds of this small example actively telling prospects the wrong thing, not because anyone made an error, but because the banner was written once and distributed everywhere. Scale that to a downline of dozens of agents across a dozen states, and the share of pages quietly carrying the wrong date can be the majority of the network, not the exception.

Checking your own site in the next fifteen minutes

This needs nothing but your own site's search box and the sources linked at the bottom of this guide.

First, find every page that states an Open Enrollment date. Search your own site for "open enrollment," "November 1," "January 15," and "January 31." Check your homepage, any seasonal landing page built for this AEP and OEP cycle, and any funnel or ad landing page running paid traffic right now, since those are the pages most likely to have been written fast and never revisited.

Second, check which exchange each page's audience actually uses. If a page targets a specific state, check that state's exchange directly rather than assuming HealthCare.gov applies. If a page is written for a multi-state or national audience, either name the exchanges that differ explicitly, the way the table above does, or drop the specific end date entirely and link to the reader's own exchange instead.

Third, attach the plan year and a check date to every claim you keep. "Open Enrollment ends January 15" with nothing else is a sentence with an invisible expiration date and no visible state. "Open Enrollment for 2027 coverage ends January 15, 2027 on HealthCare.gov, current as of October 2026" is a sentence a reader, a regulator, or an AI assistant can all check against the same public source.

Fourth, put a reminder on your own calendar for the Fourth Circuit's decision. This is the one piece of this story that is not yet finished. Whichever way No. 26-1938 comes out, it is worth a five-minute check against HealthCare.gov the week it's decided, rather than waiting for next AEP to notice the calendar moved again.

None of that fifteen-minute version requires anything beyond a search box and a free afternoon. If your site only has one or two pages that mention a specific date, doing it yourself this week is probably faster than scoping out a vendor to do it for you. Where the DIY version stops being worth it is scale: a dozen state landing pages, a few seasonal funnels, and a downline of other agents' sites all carrying some version of the same sentence is a lot of individually small checks that add up to a real afternoon, and one you'd have to repeat the next time a court docket like this one moves.

How we keep a date like this current

This is the same standard every guide on this blog argues for, applied to our own pricing: we re-fetched the Digital Foundation page live before writing this section, rather than quoting it from memory, so we weren't about to repeat the mistake this guide is warning against.

Digital Foundation's Starter tier runs $247 a month and ships 7 new pages a month, 2 blog posts, 2 location pages, 2 answer pages, and 1 custom page, alongside a full SEO/AEO checklist. Pro runs $497 a month and adds up to 14 to 17 new pages a month across blog, location, and answer content, plus a 24/7 AI voice receptionist. Scale runs $997 a month and ships up to 71 new pages a month, roughly one blog post, one location page, and one answer page every business day.¹¹ Every subscription tier includes a free look before billing starts.¹¹

The reason that matters for a guide about a date tied to an open court docket: a location page or FAQ answer we ship for a multi-state agency isn't a one-time publish with a number typed into it once. It's content that states which exchange it's talking about, cites the source, and gets revisited on a real schedule, the same way this guide names the exchange for every date it states, rather than a seasonal landing page nobody looks at again until a client calls confused in December.

We build on Astro, which ships zero JavaScript by default, so a page like this one arrives as finished HTML rather than a runtime the browser has to boot before anything loads. Our builds score 90+ on Lighthouse performance on both mobile and desktop, and some score 100, which matters for a practical reason here: a state-specific Open Enrollment answer a prospect can't load fast enough on a phone during the exact six weeks that matter never gets read closely enough for the correct date to matter in the first place.

What changes for your agency

None of this promises a ranking position, a citation, or a specific enrollment outcome, because none of those can be promised honestly. What it changes is narrower and more concrete.

The underlying lesson isn't really about Open Enrollment specifically. It's that a fact which looks permanent, a date, a count, a rule, can be sitting on top of an open court docket you never checked for. The only real defense is a page that names its source and its check date, so staleness is visible instead of silent.

Questions agents ask