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Each year, the Affordable Care Act (ACA) gives Small Group employers a valuable opportunity to enroll in medical coverage without having to meet standard participation or employer contribution requirements.

Known as the Special Open Enrollment Window (SOEW), this annual period runs from November 15 through December 15, with coverage effective January 1, 2027.

For small businesses that struggle to meet a carrier’s minimum participation or contribution requirements, the SOEW can open the door to group medical coverage that may otherwise be unavailable during the year.

Important: Word & Brown’s Submission Deadline Is December 4

Although the ACA’s annual Special Open Enrollment Window runs through December 15, Word & Brown’s submission deadline for January 1, 2027, SOEW cases is Friday, December 4, 2026.

The SOEW provides a limited annual exception to standard participation and employer contribution requirements, and carriers generally apply their SOEW submission rules and deadlines strictly. All other eligibility and underwriting requirements still apply.

Word & Brown’s December 4, 2026, submission deadline gives our Underwriting team time to review each case for completeness, confirm that all other underwriting requirements have been satisfied, identify and resolve any outstanding issues, and prepare a complete submission for the carrier before its deadline.

That lead time is especially important during the busy fourth-quarter enrollment season. Brokers planning to use the SOEW should begin working with their Word & Brown representative early and plan around the December 4 W&B submission deadline to help protect the group’s January 1 effective date.

What the SOEW Allows

Under the ACA, a small business employer that cannot satisfy applicable employer contribution or group participation requirements has an annual opportunity to obtain Small Group medical coverage during the November 15–December 15 window.

The SOEW does not waive other eligibility or underwriting requirements. Groups must still qualify as eligible Small Group employers and satisfy the carrier’s other applicable requirements, including submitting required documentation within established deadlines.

Word & Brown publishes annual Small Group SOEW Guidelines for California and Nevada detailing participating carriers’ requirements, submission procedures, documentation, and other important underwriting information. Brokers should review the applicable 2027 guidelines carefully before submitting a case.

A New Consideration for California Groups: Health Net’s Market Exit

This year’s SOEW may be particularly useful for some California employers affected by Health Net’s announced exit from the California commercial group market.

Health Net has announced that it will discontinue its California commercial group business, including Small Business group medical plans. Many existing commercial group policies are expected to end February 28, 2027, although specific termination dates may vary based on the employer’s contract.

Affected Health Net Small Group employers will need to transition to replacement coverage. For an employer that would otherwise have difficulty satisfying another carrier’s standard participation or contribution requirements, the 2027 SOEW may provide an opportunity to make that transition early, with new coverage effective January 1, 2027.

Rather than waiting until Health Net coverage ends, brokers may want to evaluate whether a January 1 transition through the SOEW makes sense for an affected client – particularly when participation or contribution requirements could otherwise limit the employer’s replacement coverage options.

A Note for Applicable Large Employers

Small Group status and the ACA’s Applicable Large Employer (ALE) status are separate determinations.

In California, the Small Group market generally includes eligible employers with up to 100 employees, while the ACA’s Employer Shared Responsibility (“employer mandate”) provisions generally apply to employers averaging at least 50 full-time employees, including full-time equivalents, during the preceding calendar year.

That means a California employer can potentially fall within the Small Group insurance market while also being an ALE under federal law. Most other states, including Nevada, define their Small Group markets as generally covering employers with up to 50 employees.

The SOEW does not suspend an ALE’s responsibilities under the ACA employer mandate. ALEs must continue to consider their obligations to offer qualifying coverage to full-time employees and their dependents and comply with applicable ACA reporting requirements.

Plan Ahead for Coverage Effective January 1, 2027 

The SOEW happens only once each year, and the turnaround for January 1 coverage is tight. Brokers with clients that struggle with participation or contribution requirements – including affected Health Net Small Group clients evaluating replacement coverage – should begin planning early.

For cases submitted through Word & Brown, remember the key date: Friday, December 4, 2026. That deadline gives our Underwriting team time to review the case, address any outstanding issues, and help ensure a complete submission is ready before the applicable carrier deadline.

Review Word & Brown’s 2027 California and Nevada SOEW Guidelines for carrier-specific requirements. Work with your Word & Brown representative to make sure all required materials are complete before submission.