CMS also released guidance on dropping COBRA coverage and applying for coverage from an exchange (in California, Covered CA) in order to receive premium tax credits.  Typically, individuals may sign up for exchange coverage during any open enrollment period or during a special enrollment period only if there is a qualifying event.  However, during Covered CA's open enrollment period, a person can voluntarily drop their COBRA coverage and enroll in exchange coverage, even if their COBRA coverage has not yet expired.  Qualified individuals may also be eligible for a premium tax credit and/or subsidized coverage.

If an individual's COBRA coverage expires outside of open enrollment, he or she is eligible for a special enrollment period and may qualify for financial assistance.  However, if an individual voluntarily drops coverage outside of the exchange's open enrollment period, he or she would not qualify for a special enrollment period.  The individual would be required to wait until the next open enrollment period to drop COBRA and apply for coverage, or may enroll when his or her COBRA coverage expires.

The CMS FAQ is available at: https://www.regtap.info/faq_viewe.php?i=1496.