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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 one-month period runs from November 15 to December 15, 2025, with coverage effective January 1, 2026.
 
For small businesses that struggle to meet participation minimums or contribution thresholds, this SOEW can be a lifeline – allowing them to obtain group coverage when it might otherwise be out of reach.

What the SOEW Allows

Under the ACA, fully insured small group carriers must accept eligible employers who apply during this annual window, regardless of employee participation or employer contribution levels. While these two requirements are waived, all other standard underwriting rules remain in effect. Groups must still submit all required documentation and meet carrier deadlines – which are typically strict, with little to no flexibility.

If you’re applying for group coverage during the window, be sure to reference our W&B Small Group SOEW Guidelines Reference for California and Nevada. This comprehensive resource outlines each carrier’s unique underwriting parameters, including submission timelines, documentation and eligibility requirements, approval procedures, and any carrier-specific rules that apply during the SOEW.

Note for Applicable Large Employers (ALEs)

If your group qualifies as an Applicable Large Employer (ALE) – generally, 50 or more full-time employees and full-time equivalents – remember that the ACA’s Employer Shared Responsibility (“employer mandate”) provisions still apply, even if you take advantage of the SOEW. ALEs must continue to offer affordable, minimum value coverage to all full-time employees and their dependents to avoid potential noncompliance penalties and maintain IRS reporting compliance.
 
In California, the Small Group market includes employers with up to 100 employees, while the federal definition of an ALE begins at 50 or more. This means some California employers may fall into both categories – a Small Group under state market segment rules but an ALE under federal law. Most other states, including Nevada, define Small Group as 1–50 employees.

Additional Resources

For a deeper dive into the compliance requirements of the ACA’s Special Open Enrollment Window, visit the W&B Compliance Wiki’s ACA section.

Finally, be sure to review the California and Nevada SOEW underwriting references available through Word & Brown; it details submission deadlines and documentation requirements for the 2025–2026 SOEW period.