The November 15 window: starting a group plan when you can't meet the usual rules

If you've tried to start a group health plan and been told your business doesn't qualify because too few of your people would sign up, or because you can't pay enough of the premium, there's one stretch of the year when that answer changes. From November 15 to December 15, a carrier has to accept a small group that misses those rules, and the coverage starts on January 1.

It's a federal rule (45 CFR 147.104), it applies every year, and most small business owners have never heard of it. This year's window opens on November 15, 2026, and December 15 is the deadline. The conversation should start well before that: getting quotes, choosing plans and signing your people up all happen before the application goes in, so the owners who do this smoothly start talking to us in October or early November.

What the usual rules are

Colorado doesn't set a minimum number of enrolled employees, and it doesn't set a minimum amount you have to pay toward their premiums. The carriers do, and each one writes its own.

The two rules work like this:

• Participation is the share of your eligible employees who have to enroll. Depending on the carrier, it runs from no set minimum at all to most of your eligible people. Employees who turn the plan down because they're covered somewhere else, like a spouse's plan, usually don't count against you.
• Contribution is how much of each employee's premium the business pays. Some carriers ask for none in particular. Others want you to pay up to half of each employee's own premium.

Through most of the year, a group that falls short of one of these gets turned away or asked to wait. In the window, it doesn't.

Who this helps

Mostly two kinds of business.

The first is the tiny business. When you have four employees and two of them are on a spouse's plan, one more person saying no can put you under a participation rule, and a group of four has no room for that.

The second is the owner whose people mostly have coverage already. Maybe your staff are young and on a parent's plan, or they're married to somebody with a good employer plan. You'd like to offer something to the two or three who need it, and on paper that's a group that doesn't qualify. In the window it does.

It also helps an owner who wants to offer a plan but can't afford to pay a large share of it yet. That's a real situation for a new business, and the window is the one time it isn't disqualifying.

What the window doesn't change

You still need at least one employee who isn't an owner. Colorado's definition of an eligible employee leaves out the owner, the owner's spouse, and business partners, so a business with nobody else on payroll can't buy a group plan, in the window or out of it. If only one employee enrolls, expect the carrier to ask for your last two quarterly wage reports, to show the business really has an employee on payroll.

The window also doesn't make a plan cheaper. Premiums are what they are, and the Division of Insurance approved an average small-group increase of 14% for 2027. Our 2027 market page has the figures for Larimer and Weld counties.

The dates for a January 1 start

Your application has to go in between November 15 and December 15. That part is the rule, and there's no grace period at the end of it.

Carriers then set their own last day for the remaining paperwork, and it isn't the same day at every carrier. Some want everything by December 20, and others take it through the end of the month. December is short, with Christmas in the middle of it, so we treat December 15 as the day everything should be finished, not the day to start.

If you miss the window, the next one is November 2027. Until then, a group that can't meet a carrier's rules is back to being turned away.

What to gather now

You don't need much to get a quote, and none of it is sensitive:

• How many people work for you, and which of them are eligible
• Each eligible employee's date of birth, and whether they'd want coverage for themselves only or for family too
• Who's likely to turn it down because they're covered elsewhere
• Your business ZIP code
• Any plan you have now, with its renewal date

The carrier will ask for payroll records later, at the application. We never need anyone's Social Security number to quote. Here's what an employee list for a quote needs, and what it doesn't.

Where we come in

Tell us how many people you have and what you're hoping to offer, and we'll check which carriers will write your group for January 1, what each one would cost, and whether the window is the way in or whether you'd qualify any time. Sometimes a different setup fits better, like a CHOICE arrangement or a QSEHRA, and we'll say so.

Tell us about your business, and do it in October or early November if you can. The window is a month long, and the quotes take time.