Open Enrollment and Your Therapy Practice: What November Through January Means for Arizona Therapists
November marks the beginning of a critical period for private practices that therapists sometimes forget to prepare for: open enrollment season. From November 1, 2025, through January 15, 2026, millions of Americans will be selecting, changing, or renewing their health insurance plans. For therapy practices that accept insurance, this three-month window brings both opportunities and challenges that can significantly impact your practice revenue and client retention.
If you've never thought strategically about open enrollment, this year is the time to start. Understanding how these insurance changes affect your practice—and preparing your clients for the transition—can mean the difference between a smooth start to 2026 and months of billing headaches, lost clients, and revenue disruption.
What Is Open Enrollment and Why Does It Matter to Therapists?
Open enrollment is the designated period when individuals can enroll in health insurance plans, switch plans, or make changes to existing coverage. For most states, including Arizona, the 2026 open enrollment period runs from November 1, 2025, through January 15, 2026, for marketplace plans.
Employer-sponsored insurance open enrollment typically occurs in the fall as well, though exact dates vary by employer. Medicare open enrollment runs October 15 through December 7, affecting clients age 65 and older.
Here's why this matters to your practice: during these few months, your clients' insurance situations can change dramatically. A client who's been in-network all year might switch to a plan where you're out-of-network. A client with a low copay might end up with a high-deductible plan where they'll pay your full fee until meeting a $5,000 deductible. Or a client might gain insurance coverage for the first time, creating new opportunities for your practice.
These changes don't just affect one or two clients—they ripple through your entire caseload. And if you're not prepared, you'll spend the first quarter of 2026 dealing with billing problems, surprised clients who can't afford sessions, and the administrative headache of updating insurance information for dozens of people.
The Timeline: What Happens When
Understanding the open enrollment timeline helps you anticipate when changes will affect your practice.
November 1 - December 15, 2025 This is when most people actively shop for and select insurance plans. Clients who enroll by December 15 will have coverage starting January 1, 2026. During this period, you'll want to proactively communicate with clients about verifying their coverage for the new year.
December 16, 2025 - January 15, 2026 Late enrollers who sign up during this window won't have coverage beginning until February 1, 2026. This creates a potential gap in coverage for clients who wait. You might have clients without insurance in January who enrolled late in December.
January 1, 2026 New coverage begins for those who enrolled by December 15. This is when the practical impacts hit your practice: new deductibles reset, copays change, and network status shifts. This is typically the busiest time for billing questions and insurance verification.
February 1, 2026 Coverage begins for late enrollers. You might still be dealing with insurance changes well into February.
How Open Enrollment Affects Your Practice Operations
The insurance changes during open enrollment create specific operational challenges for therapy practices.
Clients Switching from In-Network to Out-of-Network
This is one of the most disruptive scenarios. A client you've been seeing for months suddenly selects a new plan that doesn't include you in their network. Maybe their employer changed insurance providers, or they chose a different marketplace plan to save money on premiums without realizing the network implications.
When this happens mid-treatment, it puts both you and the client in a difficult position. The client may not be able to afford your out-of-network rate or may need to meet a much higher out-of-network deductible before insurance covers anything. You're faced with potentially losing an established client or adjusting your fee structure.
Some clients will qualify for transition of care or continuity of care provisions, which allow them to continue seeing you at in-network rates for a limited time while they transition to a new provider. However, these provisions typically require the client to apply within 30 days of coverage beginning and may only cover a few months of continued care.
Deductible Resets Creating Payment Surprises
Even when clients stay with the same insurance company, their out-of-pocket costs often change dramatically on January 1 when annual deductibles reset.
A client who had been paying a $30 copay for sessions in December might suddenly owe your full fee—potentially $100 to $150 per session—until they meet their annual deductible. If they have a high-deductible health plan, they might need to pay out-of-pocket for therapy for months before insurance kicks in.
Many clients don't understand how deductibles work or don't remember that they reset annually. The first session of January often comes with sticker shock and difficult conversations about whether they can afford to continue therapy.
Important: As an in-network provider, you are legally required to collect deductibles, copays, and coinsurance from clients. Your provider contract with insurance companies obligates you to bill and collect these amounts exactly as determined by the insurance plan. Routinely waiving or reducing these amounts can violate your contract and potentially federal anti-kickback laws. The only legitimate exception is documented financial hardship with proper procedures followed.
Plan Changes Within the Same Insurance Company
Clients might stay with the same insurance carrier but switch to a different plan within that network. This can change copay amounts, deductible levels, and even whether certain services require preauthorization.
You'll need to re-verify benefits even for clients who technically still have the same insurance company name because their plan specifics may have completely changed.
Administrative Burden of Re-Verifying Benefits
January typically means re-verifying insurance benefits for a significant portion of your caseload. Each verification takes time—calling the insurance company, navigating phone trees, waiting on hold, documenting the information.
If you have 30 clients and 20 of them changed some aspect of their coverage, that could mean 10-15 hours of administrative work just verifying benefits. This time comes directly out of your income-generating hours or requires staff time if you employ someone to handle billing.
Proactive Communication: Your Best Defense
The most effective way to minimize disruption from open enrollment is proactive communication with your clients. Don't wait until January when problems arise—start these conversations in November.
What to Tell Clients in November
During November sessions, mention open enrollment to all clients who use insurance. You might say something like:
"November is open enrollment season for health insurance. If you're planning to change plans or if your employer is changing insurance, I want to make sure we stay connected. Before you finalize any insurance changes, please check whether I'm in-network with your new plan. I'm happy to provide my NPI and tax ID if you need to verify coverage."
This simple conversation plants a seed and reminds clients to think about their therapy coverage when making insurance decisions.
Provide Verification Tools
Make it easy for clients to verify your network status. Consider creating a simple handout or email template that includes:
Your full name and credentials as they appear in insurance directories
Your National Provider Identifier (NPI) - both Type 1 and Type 2 if applicable
Your Tax ID (EIN)
Your office address
Questions clients should ask their insurance company to verify coverage
When clients have this information handy during open enrollment, they're more likely to check whether you're in-network before finalizing their plan selection.
December Check-Ins
As December approaches, follow up with clients whose insurance you know might be changing. Send an email or mention during sessions:
"I wanted to check in about insurance for next year. Are you anticipating any changes in coverage or policy? I want to make sure we have your updated information so there aren't any surprises in January."
This gives clients one last prompt before the new year begins.
Helping Clients Navigate Their Options
When a client discovers you're not in their new network, they need guidance on their options. Rather than simply accepting that they can't afford to continue therapy, help them explore alternatives.
Out-of-Network Benefits
Many clients don't realize their insurance includes out-of-network benefits. While these benefits typically provide lower reimbursement than in-network services, they can still make therapy more affordable.
If a client has out-of-network coverage, you might provide superbills—detailed receipts that clients can submit to their insurance company for reimbursement. While the client pays you upfront, they may receive 50-80% back from their insurance company depending on their plan.
Not every plan includes out-of-network benefits, but it's worth investigating before assuming continuation isn't possible.
Sliding Scale and Payment Plans
For clients who can't afford full fee but whom you don't want to lose, you need to be very careful about how you handle this if you're an in-network provider.
Critical compliance note: If you're in-network with a client's insurance, you cannot routinely waive or discount their deductible, copay, or coinsurance. This violates both your provider contract and potentially federal anti-kickback statutes. The only legitimate exceptions are:
Documented financial hardship - You must have a formal policy requiring clients to demonstrate genuine financial hardship through documentation (not just verbal claims). This must be applied consistently and documented thoroughly.
Good faith collection efforts - If you've made reasonable attempts to collect the patient-owed amounts and been unsuccessful, you may write off the balance. However, this can't be a routine practice or done upfront.
For out-of-network situations or private pay clients, you have more flexibility with sliding scales and payment arrangements since you're not bound by insurance contract terms.
Warm Handoffs to In-Network Providers
If continuing with you truly isn't financially feasible for a client, provide a thoughtful referral to in-network providers. Rather than just giving them a list of names, offer to help facilitate the transition:
Provide 2-3 specific referrals based on the client's needs
Offer a transition session focused on summarizing treatment progress
With the client's consent, provide a brief summary to the new therapist to ensure continuity of care
A warm handoff demonstrates that you care about the client's wellbeing beyond your own practice, and clients remember that professionalism.
Insurance Changes Mid-Treatment: Legal and Ethical Considerations
When a client's insurance changes during active treatment, several legal and ethical issues arise that you need to handle carefully.
The Legal Requirement to Collect Patient Costs
This is critical information that many therapists don't fully understand: as an in-network provider, you are legally required to collect deductibles, copays, and coinsurance from your clients.
Your provider contract with insurance companies includes language that obligates you to bill and collect patient cost-sharing exactly as determined by the insurance plan. This isn't optional. Routinely waiving, discounting, or failing to collect these amounts can result in:
Contract violations - Insurance companies can terminate your provider agreement for breach of contract
Federal anti-kickback statute violations - Waiving copays to induce patients to use your services can violate federal law
False Claims Act violations - If you routinely waive patient costs, you're misrepresenting the actual cost of services to the insurance company
ERISA violations - You may be interfering with the contractual obligations between employers and their insurance plans
Significant financial penalties - Legal cases have resulted in millions of dollars in damages
The only legitimate reasons to waive or reduce patient cost-sharing are:
1. Documented Financial Hardship You must have a formal, written financial hardship policy that requires:
The patient to request assistance and provide financial documentation
An objective assessment of the patient's financial situation
Consistent application across all patients
Thorough documentation of the hardship determination
The hardship cannot be advertised or routinely offered
2. Good Faith Collection Efforts Failed If you've made reasonable, documented attempts to collect the patient-owed amounts and been unsuccessful, you may write off the balance. However:
You must actually attempt collection first
This cannot be your routine practice
You cannot decide upfront that you won't collect
You must document your collection efforts
What you absolutely cannot do:
Advertise that you'll accept "insurance as payment in full"
Routinely waive copays without assessing financial hardship
Collect copays only when patients have secondary insurance that pays them
Use financial hardship forms without actually evaluating financial need
Offer copay waivers as an inducement to choose your practice
Informed Consent and Fee Changes
If a client's insurance change means they'll now pay significantly more per session, this constitutes a material change in your agreement. Best practice is to have a conversation about the change before continuing treatment at the new rate.
Document this conversation and ensure the client understands and agrees to the new financial arrangement. This protects both you and the client and prevents misunderstandings that could damage the therapeutic relationship.
Be especially clear about collection requirements: If you remain in-network with the client's new insurance, explain that you are legally required to collect their deductible, copay, or coinsurance as determined by their insurance plan. This isn't optional or negotiable—it's a contractual and legal obligation. Clients need to understand that you cannot waive or discount these amounts except in cases of documented financial hardship following your formal policy.
Continuity of Care Provisions
As mentioned earlier, some insurance plans offer continuity of care or transition of care provisions for clients in active treatment whose provider is no longer in-network. These provisions vary by state and insurance company.
In Arizona, certain protections exist, but they're not universal. Familiarize yourself with how major insurance carriers in your area handle these transitions so you can guide clients appropriately.
Termination vs. Transition
From an ethical standpoint, you can't simply terminate a client because their insurance changed, especially if they're in crisis or dealing with serious mental health issues. You have a professional obligation to ensure appropriate transition or continuation of care.
However, you must balance this ethical obligation with legal compliance requirements. If you remain in-network with their new insurance, you cannot waive their higher copay or deductible to make sessions more affordable—doing so violates your provider contract and federal regulations.
Options that comply with both ethical and legal requirements include:
Helping the client apply for continuity of care provisions through their insurance
Providing several transition sessions while they find a new in-network provider
If you're no longer in-network with their insurance, you may have more flexibility with fee arrangements
Connecting them with low-cost community resources or providers who accept their insurance
If the client qualifies for documented financial hardship under your formal policy, that option may be available
What This Means for Your Practice Revenue
Open enrollment season has real financial implications for therapy practices. Understanding and planning for these impacts helps you maintain financial stability.
Revenue Dips in January and February
Many practices experience revenue dips in the first quarter of the year due to open enrollment changes. Clients who can't afford the new costs reduce session frequency or discontinue entirely. Clients with high deductibles might delay scheduling until they've met their deductible through other medical expenses.
If you know this dip is coming, you can plan for it financially rather than being caught off guard.
The Value of Diversified Payer Mix
Practices that rely too heavily on a single insurance company are most vulnerable during open enrollment. If a major employer in your area switches from the insurance carrier you're with to a different one, you could lose multiple clients simultaneously.
A diversified payer mix—being credentialed with multiple insurance companies plus maintaining some private pay clients—provides more stability when individual carriers experience changes.
Private Pay as a Buffer
Maintaining a portion of your practice as private pay provides a buffer against insurance-related disruptions. Private pay clients don't experience the same January chaos around deductibles and network changes.
Some therapists use open enrollment season to strategically adjust their payer mix, perhaps taking on more private pay clients to reduce insurance dependency.
Action Steps for Your Practice This November
If you're reading this during open enrollment season, here are immediate steps you can take to protect your practice and support your clients:
Week 1 of November:
Send an email to all insurance-based clients reminding them about open enrollment
Include information on how to verify you're in-network with potential new plans
Provide your NPI and Tax ID for easy reference
Throughout November and December:
Mention open enrollment in sessions with insurance clients
Ask if anyone is planning to change insurance
Offer to help them verify coverage before they finalize changes
Mid-December:
Follow up with clients who mentioned potential insurance changes
Confirm whether changes are happening and what the new insurance will be
Schedule time in early January for benefit verifications
Early January:
Verify benefits for all clients with new or changed insurance
Have conversations about any fee changes before providing services
Clearly communicate your legal obligation to collect deductibles, copays, and coinsurance
Provide clients with information about their payment responsibilities under their new plans
Update your billing systems with new insurance information
Ensure your financial hardship policy (if you have one) is properly documented and compliant
Throughout January:
Be prepared for payment questions and concerns
Have clear policies for handling deductible periods that comply with your provider contracts
Document all financial hardship requests according to your policy
Be ready to discuss options for clients whose costs increased
Never offer to waive or reduce copays/deductibles upfront—this violates your contract
The Bigger Picture: Building a Resilient Practice
Open enrollment isn't just a November phenomenon—it's an annual reminder of the complexity and challenges of accepting insurance in a therapy practice. Every year, you'll face similar disruptions as clients' coverage changes.
Building resilience into your practice means creating systems and strategies that minimize these disruptions. This might include:
Maintaining up-to-date information on which insurance plans you accept
Creating template communications for open enrollment season
Developing clear policies for handling insurance changes mid-treatment
Considering which insurance panels provide the most stable, reliable reimbursement
Strategically managing your payer mix to balance insurance and private pay
Some therapists eventually decide that the administrative burden and financial uncertainty of insurance isn't worth it and transition to private pay. Others find ways to make insurance work efficiently for their practice. There's no right answer—only what works best for your practice goals and the population you serve.
When Open Enrollment Becomes Too Much
If you find that managing insurance changes during open enrollment (and throughout the year) is consuming too much time and energy, it might be time to evaluate whether you need support.
Many therapy practices benefit from working with credentialing and billing specialists who understand the intricacies of insurance and can handle the administrative burden. This allows you to focus on clinical work while someone else manages verifications, re-credentialing, and billing issues.
Other practices decide to simplify by reducing the number of insurance panels they accept, focusing only on the most prevalent and best-paying insurance companies in their area.
Still others transition partially or completely to private pay, offering superbills for clients who have out-of-network benefits but no longer dealing with the direct billing complexity.
There's no shame in admitting that insurance administration isn't your strength or isn't how you want to spend your time. The key is recognizing when it's negatively affecting your practice and making strategic changes.
Open Enrollment as an Opportunity
While this article has focused heavily on the challenges of open enrollment, it's worth noting that this period also creates opportunities.
Some clients gain insurance coverage for the first time during open enrollment, making therapy newly affordable. Others switch to plans where you're in-network, potentially reducing their out-of-pocket costs and making them more likely to maintain regular sessions.
Additionally, open enrollment is a natural time to evaluate your own insurance situation as a business owner. Are you maximizing available tax deductions related to your business insurance? Is your professional liability insurance still appropriate for your practice size and scope?
Use this season as a prompt to review not just your clients' insurance but your own business insurance needs and strategic planning.
The Bottom Line
Open enrollment season—November through January—significantly impacts therapy practices that accept insurance. Proactive communication with clients, clear policies for handling insurance changes, and strategic planning can minimize disruptions and protect your practice revenue.
Don't wait until January when problems arise. Start conversations with your clients now about verifying their coverage for 2026. Prepare your administrative systems for the influx of benefit verifications you'll need to complete. And consider whether your current approach to insurance is serving your practice well or whether changes might be needed.
The therapists who navigate open enrollment most successfully are those who anticipate the challenges, communicate clearly with clients, and have systems in place to handle the inevitable changes efficiently. With preparation and planning, you can turn what feels like an annual headache into a manageable part of your practice operations.
Managing insurance credentialing and billing feeling overwhelming? Start My Practice AZ helps Arizona therapists streamline practice operations, including insurance credentialing, billing systems, and strategic planning. Contact us to learn how we can help your practice thrive through open enrollment and beyond.
