Terminated Employee, Cobra, and ACA


Super Genius
I was contacted this week by an individual who expects his employment to be terminated around mid-October. He will be eligible for Cobra, but it will be expensive and he wants to consider options on the Marketplace exchanges as well. I know he will qualify for a SEP because of his loss of coverage through his job.

I also know that he will have at least 60 days to elect Cobra from his termination date, which carries him into mid-December. He then has 45 days to make his first premium payment, or until the end of January or so. My understanding is that he would be covered during this entire time period.

My question is this: since open enrollment begins November 15th for coverage to start January 1st, is there any reason for him to exercise his SEP early, before open enrollment? Why can't he just wait and see if he needs any coverage between his termination in October and the end of the year, and pay the premium if he needs to?