Availability of short-term health insurance in Tennessee

Yes. As of 2024, there were at least five insurers offering short-term health insurance in Tennessee.

The average monthly premium for a short-term health insurance plan sold in Tennessee was $176.92 in 2023, according to data from IHC Specialty Benefits.

Tennessee does not limit the duration of short-term health insurance plans, so the state defaults to the federal rules. The Trump administration issued regulations in 2018 that allow short-term medical plans to have initial terms of up to 364 days, and total duration, including renewals, of up to 36 months.

However, those federal limits will change in 2024 under new Biden administration rules for short-term health plans. Short-term plans issued or sold on or after September 1, 2024 will be limited to total durations of no more than four months, including renewals.

But insurers can impose shorter maximum terms and can opt not to allow renewals. Some of the insurers that offer short-term health insurance in Tennessee allow consumers to buy up to 36 months of coverage, while others cap their plans at six months.

If you’re in need of health insurance coverage in Tennessee outside of the annual open enrollment period for ACA-compliant major medical plans (November 1 to January 15), your first step should be to see whether you’re eligible for a special enrollment period that would allow you to enroll in an ACA-compliance plan.

There are a variety of qualifying life events that will trigger a special enrollment period and allow you to buy a plan through the health insurance exchange in Tennessee. These plans are purchased on a month-to-month basis, so you can enroll in one (with a premium subsidy if you’re eligible) even if you’re only going to need it for a few months before another policy takes effect.

The annual open enrollment period for ACA-compliant major medical plans runs from November 1 through January 15. And it’s important to understand that financial assistance through the Tennessee health insurance exchange is larger and more widely available than it used to be, thanks to the American Rescue Plan (this will be the case through the end of 2025, and possibly beyond that if Congress issues another extension of the American Rescue Plan’s subsidy enhancements).

Short-term health insurance plans can be purchased in Tennessee by applicants who meet the underwriting guidelines the insurers use. In general, this means being under 65 years old (some insurers put the age limit at 64 years) and in fairly good health.

Short-term health medical insurance plans typically include blanket exclusions for pre-existing conditions, so they are not adequate or affordable (due to the cost of monthly premiums and other out-of-pocket costs) for someone in the Volunteer State who is in need of ongoing medical care.

Before you sign up for a short-term plan, make sure you understand the specific healthcare benefits the plan will provide. For example, most short-term health insurance plans do not cover outpatient prescription drugs. Some do include prescriptions in their covered benefits, but you’ll want to make sure that you’re not mistaking a prescription discount plan for real prescription benefits.

You’ll also want to understand whether the plan imposes specific dollar limitations on healthcare services such as inpatient hospital stays, surgery, etc. (in addition to the plan’s overall benefit maximum).

From Knoxville to Memphis, there are times when short-term health insurance might be the only option available, such as:

• If you missed open enrollment for ACA-compliant coverage and do not have a qualifying event that would trigger a special enrollment period.
• If you’re not eligible for Medicaid or a premium subsidy in the exchange, an ACA-compliant plan might be unaffordable.

People who are ineligible for premium subsidies include:

• Those who earn too much to qualify for subsidies (normally this is more than 400% of the poverty level, although the American Rescue Plan and Inflation Reduction Act have eliminated that income cap through the end of 2025). If your ACA-specific modified adjusted gross income is just a little above the subsidy-eligible threshold, there are steps you can take to reduce it.)
• Those who earn less than the poverty level in states that haven’t expanded Medicaid. (Tennessee has not expanded Medicaid.)
• People who cannot use the exchange/Marketplace or Medicaid due to an undocumented immigration status.

Insurers that offer short-term plans in Tennessee are required to file the rates and plans with the Tennessee Department of Commerce and Insurance, and there are specific state rules that apply to rate and form filing in Tennessee for plans that aren’t subject to ACA (Obamacare) regulations (including short-term health plans).

Several sections of Tennessee insurance statute Title 56) apply to short-term plans sold in the state, including

• 56-7-2301 – 2368, Mandated Insurer or Plan Coverage
• 56-7-2401 – 2410, Mandated Scope of Practice
• 56-7-2501 – 2508, Mandated Insurer or Plan Options
• 56-7-2601 – 2606, Mandated Offerings of Coverage

Until mid-2019, Julie Mix McPeak served as the insurance commissioner for Tennessee. McPeak was also the president of the National Association of Insurance Commissioners (NAIC) when the NAIC submitted a letter to HHS that was generally supportive of the then-proposed rule change to expand access to short-term health insurance plans. In particular, the NAIC supported the provision to allow short-term plans to have initial terms of up to 364 days, instead of the three-month limit that was imposed under a regulation finalized by the Obama administration in 2016.

McPeak expressed support for the expansion of short-term plans, while also noting how important it is for consumers to understand the benefits covered by the plan they are considering and how short-term healthcare insurance plans differ from ACA-compliant plans.

It’s noteworthy that Northeastern Tennessee’s Tri-Cities has the highest rate of pre-existing conditions in the United States: 41% of adults in the area have health conditions that would have prevented them from buying individual-market health insurance prior to 2014 (when the ACA reformed that market and banned medical underwriting). But short-term health insurance plans still use medical underwriting, and the policies generally do not cover pre-existing conditions. Excluding coverage for pre-existing conditions can make a short-term policy appear more affordable than an ACA-compliant or Obamacare policy.