You now require a special enrollment period to enroll.

As explained in the glossary section of the exchange website Healthcare.gov, a special enrollment period is “a time outside of the open enrollment period during which you and your family have a right to sign up for health coverage. In the marketplace, you generally qualify for a special enrollment period of 60 days following certain life events that involve a change in family status (for example, marriage or birth of a child) or loss of other health coverage. If you don’t have a special enrollment period, you can’t buy insurance through the marketplace until the next open enrollment period.”

Other triggering events that can require the exchange to allow an employee a special enrollment period include: errors, misrepresentations, or inaction by an officer, employee, or agent of the exchange or HHS; obtaining the status of a citizen; or exceptional circumstances, including natural disasters like earthquakes or floods.

So, in many ways, special enrollment rights in the exchanges look a lot like the special enrollment rights provided in HIPAA for employer-sponsored plans. For employers, this means that determining whether or not to continue a plan in its current form, to terminate coverage or to change eligibility for coverage, should not assume that employees who lose coverage would be barred from the exchanges for the remainder of 2014.