Five ways the American Rescue Plan might slash your health insurance costs

March 18, 2021/in COBRA, costs of coverage, health insurance premiums, premium tax credit /by wpmaddoxins

If you’re among the millions of Americans who are uninsured or who buy their own health insurance in the individual market, the American Rescue Plan (ARP) has just significantly changed the rules – and changed them in a way that likely improve your access to affordable comprehensive health insurance.

Thanks to the legislation – signed last week by President Biden – premium subsidies are larger and available to more people in 2021 and 2022. Many people who are receiving unemployment compensation in 2021 can now qualify for premium-free health insurance that provides robust benefits. And people who received excess premium subsidies in 2020 do not have to repay that money to the IRS when they file their 2020 tax return.

These improvements – although temporary and part of a massive bill designed to help the country recover from the COVID pandemic – will make it much easier for people to afford high-quality health insurance. But they’ve also generated a great deal of questions and confusion, especially among people who wonder whether they need to reconsider the plan choice they already made for 2021.

And the timing of these changes coincides neatly with a COVID-related enrollment period available nationwide. In most states, it continues through May 15, and in most states it’s an opportunity for people to newly enroll or switch from one plan to another, with coverage that takes effect the month after you enroll.

Should you use this window to enroll or make a plan change now that the ARP has been enacted? It depends, although you’ll definitely want to at least take another look at your coverage options. Here are some of the most common scenarios – and questions that people should be asking about them – right now:

1. You’re enrolled in an off-exchange ACA-compliant plan

Off-exchange plans are essentially the same as on-exchange plans, but people purchase them directly from the insurance company instead of going through the health insurance marketplace. If you know for sure that you’re not eligible for a premium subsidy, it’s fine to be enrolled off-exchange. But if you might be subsidy-eligible, the only way to get that subsidy – either upfront or claimed later on your tax return – is to enroll through the exchange.

Thanks to the American Rescue Plan, applicants with household incomes above 400% of the federal poverty level – who were previously ineligible for a subsidy – may find that they now qualify for a subsidy. And depending on where they live and how old they are, the subsidy could be substantial.

If you’re enrolled off-exchange, it’s definitely in your best interest to check out the on-exchange options and see if you’d qualify for a subsidy under the new rules.

If you’re in a state that uses HealthCare.gov, the new subsidies and premium amounts will be available for browsing as of April 1. (The 15 state-run marketplaces are working on this as well, and will display the new subsidy amounts as soon as possible.) But CMS has clarified that people should still enroll by the end of March in order to have coverage April 1, and then come back to the marketplace after the beginning of April to activate the new subsidies. (Applications submitted before April 1 will only have the current, pre-ARP subsidies built-in, although enrollees would then still be able to collect the full subsidy amount when they file their 2021 tax returns).

If you’re enrolled off-exchange and planning to switch to the on-exchange version of your current plan, your insurer might be willing to transition any accumulated out-of-pocket expenses you may have incurred thus-far this year. But this is not required; you’ll want to reach out to your insurer to see if this is something they’d allow.

Depending on where you live and the plan you’ve selected, the same plan (with the same medical provider network) may or may not be available on-exchange. And if you’re switching to a different policy on-exchange, your out-of-pocket spending will reset to $0 on the new plan.

So switching to an on-exchange plan is not necessarily the best option for everyone – it will depend on plan availability, provider networks, how much you’ve spent out-of-pocket already this year, and how much your premium subsidy will be if you enroll in a plan through the exchange.

2. You’re enrolled in a health plan that’s not ACA-compliant

Right now, you may have coverage through a short-term health insurance plan, a health care sharing ministry plan, a fixed indemnity plan, a direct primary care membership, a Farm Bureau plan, or a grandmothered or grandfathered health plan. Chances are, you’ve chosen this option because the monthly premiums fit into your budget, and ACA-compliant health coverage did not – at least as of the last time you checked. But it’s time to check again.

Healthy people with income above 400% of the poverty level have long been drawn to these alternative types of coverage, as have some people with incomes a little under 400% of the poverty level who only qualified for fairly small premium subsidies. But for 2021 and 2022, as a result of the ARP, the subsidies are much larger and there’s no longer a subsidy cliff.

So before the current COVID-related enrollment window ends (May 15 in most states), you’ll want to check out your marketplace options. You might be pleasantly surprised to see that you can get comprehensive ACA-compliant health insurance – at least for this year and next year – at a much lower premium than you might have seen the last time you checked. (Again, note that if you’re browsing plan options before April 1 in most states, you won’t yet be able to see the more robust premium subsidies. But you’ll still be able to claim them on your 2021 tax return for any months in 2021 that you were enrolled.)

3. You’re enrolled in a Bronze plan through the exchange

If you’re currently enrolled in a Bronze plan through the exchange, you may have picked it because the premiums were lower than Silver, Gold or Platinum coverage options. Your Bronze plan may have been entirely free after your subsidy was applied.

You’ll still have a low (or free) premium under the ARP, but it’s in your best interest to actively compare it to the other available options during the current COVID-related enrollment period. You may find that you can now qualify for a very low-cost – or maybe free – Silver plan, which would have more robust benefits than your Bronze plan. This is especially true if you’re eligible for cost-sharing reductions (CSR), as these are essentially a free upgrade on your health coverage benefits. (CSR benefits are available in 2021 to a single individual earning up to $31,900, and to a family of four earning up to $65,500. These amounts are higher in Alaska and Hawaii.)

Before you make a plan switch, however, you’ll want to pay attention to the maximum out-of-pocket limits for the plans at a higher metal level. If you’re not eligible for CSR (ie, your income is above 250% of the poverty level), you might find that the available Silver plans have out-of-pocket limits that are similar to what you have with your Bronze plan. Depending on how you anticipate using your plan during the year, it may or may not make sense to pay a higher premium to upgrade your coverage.

If you anticipate high claims costs that will result in hitting the out-of-pocket maximum regardless of what plan you have, you might not come out ahead with an upgraded plan, once you account for your total out-of-pocket costs and premiums. But if you rarely have medical needs, the upgraded plan might save you money via a lower deductible and lower copays for things like office visits and prescription drugs.

As always, take all of the factors into consideration: Total premiums, out-of-pocket maximum, and how the plan might cover your medical costs if you don’t expect to meet that out-of-pocket maximum during the year.

If you picked a Bronze plan because you wanted to contribute to a health savings account (HSA) and needed to enroll in an HSA-qualified high-deductible health plan (HDHP), it’s worth checking to see if there are any HDHPs available in your area at a higher metal level. While it’s common to see Bronze HDHPs, there are also Silver and even Gold HDHPs in many areas. With the new subsidies created by the ARP, you might find that you can still maintain your HSA eligibility while also having a health plan with lower out-of-pocket costs that doesn’t cost you too much more in monthly premiums.

4. You’ve lost, or will soon lose, your job — and your health coverage

If you recently lost or will soon lose your job – and your health insurance – you’ve got some decisions to make. You might have access to COBRA or state continuation coverage (mini-COBRA), and you’ll also have access to a special enrollment period during which you can sign up for an individual/family health plan.

Under ARP Section 9501, the government will cover the full premium costs for COBRA or mini-COBRA from April 1 through September 30, 2021. (Note that this is not available if you voluntarily left your job.)

If you were laid off (or experienced an involuntary reduction in hours that resulted in a loss of health coverage) any time in the last 18 months and were COBRA-eligible but either declined it or later terminated it, you can opt back into COBRA in order to take advantage of the new subsidy. However, the subsidy does not extend your initial COBRA termination date, which is still, in most cases, 18 months after your COBRA would have begun if you had opted in from the start. So if you were first eligible for COBRA on October 1, 2019, your COBRA and your COBRA subsidy will end on April 30, 2021 (ie, 18 months later). This also applies to state continuation plans, which are often shorter in length than COBRA

If you’re receiving unemployment compensation at any point this year, you’ll also be eligible for a $0 premium Silver plan in the marketplace, with the most robust level of cost-sharing reductions. (CMS has clarified that it might take a while to get the details of this programmed into HealthCare.gov, but enrollees will be able to log back into their accounts later in the year to activate the larger subsidies, and there’s always the option to just claim them on your tax return after the end of the year.)

So should you take the fully subsidized COBRA coverage or the fully subsidized marketplace plan? It depends, but there are several factors to consider:

If you elect COBRA, what’s your plan for the final quarter of the year? Would you be able to pay full price once the government subsidy ends?
We don’t yet have federal guidance on whether the end of the government-funded COBRA subsidies will trigger a special enrollment period for marketplace plans, although we assume that it will. (The end of employer subsidies for COBRA does trigger a special enrollment period.) But assuming it does, would you want to switch to a marketplace plan at that point?
If you’ve incurred out-of-pocket costs under your employer’s plan thus far in 2021, COBRA might be the better choice, as you won’t have to start over on the out-of-pocket costs for a new plan. But you’ll still want to consider what you’ll do after September, and whether it will be more cost-effective to pay full price for COBRA for the final months of the year, or start over with a new plan at that point.
If you opt to switch to a marketplace plan, pay close attention to the provider networks and covered drug lists. Even if the marketplace plan is issued by the same insurance company that provides or administers your employer’s plan, the benefits and provider network might be quite different on the individual/family plan.

If you’re already enrolled in a marketplace plan and you’re receiving or have received unemployment compensation this year, you’ll want to take a close look at your coverage options. If you’re currently enrolled in a Bronze plan, be sure to check out the $0 premium Silver plan with robust cost-sharing reductions that may be available to you under the ARP, due to your unemployment compensation in 2021.

5. You’re already enrolled in the marketplace and happy with your plan

About 15% of current marketplace enrollees pay full price for their coverage, usually because they earn more than 400% of the poverty level and thus aren’t subsidy-eligible. But if you’re in this group, you may be eligible for a subsidy under the ARP.

Millions of other marketplace enrollees are receiving premium subsidies, and although their available subsidy amounts are likely to be larger under the ARP, they may not want to make any changes to their coverage.

If you’re already enrolled in a marketplace plan and certain that your current plan is the best option for your circumstances, you don’t need to do anything at all. If you qualify for an additional premium subsidy amount, it will be retroactive to January 2021 and you’ll be able to claim it when you file your 2021 taxes.

But you may want to log back into your marketplace account and claim your new or additional subsidy amount, so that it can be paid to your insurer on your behalf each month for the rest of 2021.

If you’re in a state that uses HealthCare.gov, CMS has confirmed that the premium subsidy amounts will not automatically update (the 15 state-run marketplaces will have their own protocols for how this is handled). So you’ll need to return to the marketplace to provide proof of your income (if you’re currently enrolled in a full-price plan and never gave your income details to the marketplace) or reselect your current plan and trigger the new subsidies.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

The post Five ways the American Rescue Plan might slash your health insurance costs appeared first on healthinsurance.org.

American Rescue Plan delivers $0 Silver premiums to unemployed

March 11, 2021/in health reform, premium tax credit /by wpmaddoxins

Although the American Rescue Plan (ARP) is about far more than just healthcare, it’s the most significant improvement to healthcare access and affordability since the Affordable Care Act.

We’ve already talked about how the new law – passed by Congress this week and signed by President Biden today – will boost premium subsidies for most marketplace enrollees in 2021 and 2022 and also protect people from having to repay excess premium subsidies from last year.

But another important provision in the legislation will provide substantial premium tax credits (premium subsidies) and cost-sharing reductions to Americans who are receiving unemployment benefits at any time this year.

Full premium subsidies + strongest level of cost-sharing reductions

Section 9663 of the American Rescue Plan ensures that most people who receive at least one week of unemployment compensation at any time in 2021 will be able to obtain a Silver plan with $0 premiums. And Section 2305 ensures that the Silver plan will also include cost-sharing reductions that bring the actuarial value of the plan to 94% (which is superior to the actuarial value of a Platinum plan).

In both cases – for determining the premium tax credit amount and cost-sharing reduction eligibility – the exchange will disregard any income above 133% of the poverty level.

The enhanced premium subsidies in the American Rescue Plan result in $0 benchmark plan premiums for buyers with income up to 150% of the federal poverty level. So people receiving unemployment compensation will end up in that category, since their counted income will be capped at 133% of the poverty level.

And although there are three levels of cost-sharing reductions, the strongest – which result in added benefits that make Silver plans more robust than regular Platinum plans – are available to people who earn no more than 150% of FPL. Since counted income will be capped at 133% of the poverty level for people receiving unemployment compensation, all of the available Silver plans will have the strongest level of cost-sharing reductions built into their benefits.

In order to qualify for the enhanced premium tax credits and cost-sharing reductions, applicants only need to receive (or be approved to receive) unemployment compensation for at least one week in 2021. The legislation states that eligible enrollees will have to attest to the fact that they’re receiving or have received unemployment compensation this year, and that HHS will issue guidance clarifying what documentation will have to be submitted to the marketplace as proof.

The enhanced premium subsidies and cost-sharing reduction benefits are then potentially available for the remainder of 2021. But this will depend on whether you again become eligible for employer-sponsored health insurance that’s considered affordable and provides minimum value.

If you do, you’ll no longer be eligible for premium subsidies or cost-sharing reductions, since those are never available for months that a person is eligible for affordable employer-sponsored coverage that provides minimum value (regardless of whether the person is enrolled in the employer’s plan or not). That would also extend to family members who are eligible to enroll in the employer-sponsored plan, as the American Rescue Plan does not, unfortunately, address the family glitch.

Provides assistance to people who would otherwise be in the Medicaid coverage gap

Under the ARP, a person who receives unemployment compensation in 2021 is considered an “applicable taxpayer” for purposes of ACA Section 36B, which determines premium subsidy eligibility.

This means that a person who is receiving unemployment compensation but whose income is still low enough to be in the Medicaid coverage gap would be eligible for a $0 premium silver plan in 2021 (The Medicaid coverage gap still exists in 14 states; this will drop to 12 states once Oklahoma and Missouri expand Medicaid eligibility this summer.)

The ARP also encourages those remaining states to expand Medicaid. It provides two years of additional federal Medicaid funding to states that newly expand eligibility as called for in the Affordable Care Act.

Enrollment window is opportunity to take advantage of subsidies

From now through May 15, Americans can take advantage of an enrollment window open nationwide – that’s part of the Biden administration’s efforts to address the ongoing COVID pandemic. So if you’re uninsured and receiving unemployment benefits (or if you’ve received them at any point this year and do not have access to an employer-sponsored plan), you can sign up for health coverage through your state’s marketplace and take advantage of the financial assistance provided by the American Rescue Plan.

In nearly every state, people who are already enrolled in a health plan through the marketplace can also use this window to switch plans.

But what if you’re in a state with a state-run marketplace that is only allowing people who don’t already have marketplace coverage to enroll during the COVID-related enrollment window? You should still be able to switch to a Silver plan (if that’s your choice), as becoming newly eligible for cost-sharing reductions is a qualifying event that will allow you to replace your existing non-Silver plan with a Silver plan that includes cost-sharing reductions.

What if you’re eligible for Medicaid?

It’s important to understand that Medicaid eligibility is not affected by the change in how income is counted for people who are receiving unemployment compensation this year.

ARP Section 9663 temporarily adjusts the rules relating to ACA Section 36B (premium tax credits) and ARP Section 2305 temporarily adjusts the rules relating to ACA Section 1402 (cost-sharing reductions). In both cases, the legislative text that disregards income above 133% of FPL for 2021 is clear in noting that it’s “for purposes of this section,” meaning that the person’s income above 133% of FPL would not be disregarded for other purposes, such as determining Medicaid eligibility, Basic Health Program eligibility (in New York and Minnesota), or whether an offer of employer-sponsored coverage is considered affordable.

If a person is eligible for Medicaid based on their regular ACA-specific modified adjusted gross income, they would continue to be eligible for Medicaid in 2021 even if they’re receiving unemployment compensation. In states that have expanded Medicaid, eligibility for adults under the age of 65 extends to 138% of the poverty level (133% plus a built-in 5% income disregard). This could potentially cause some confusion in terms of the financial assistance for which people are eligible if they’re receiving unemployment compensation in 2021. But the crux of the matter is that the externally imposed temporary income cap of 133% of the poverty level does not apply for the determination of Medicaid eligibility, whereas it does apply for the determination of premium subsidies and cost-sharing reductions.

And as was the case in 2020, the additional COVID-related federal unemployment benefits (which have been extended through September 6) are not counted as income when determining eligibility for Medicaid.

So a person in a state that has expanded Medicaid will still be eligible for Medicaid in 2021 with an income of up to 138% of FPL. (That amounts to $17,774 for a single person in 2021.) As always, anyone eligible for Medicaid is not eligible for premium subsidies or cost-sharing reductions; this continues to be true for people receiving unemployment compensation at some point in 2021.

And a person in New York or Minnesota who is eligible for Basic Health Program coverage (the Essential Plan in New York; MinnesotaCare in Minnesota) will continue to be eligible for that coverage (as opposed to $0 premium silver plans in the marketplace) even if they receive unemployment compensation at some point this year. But there are premiums associated with Basic Health Program coverage.

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