Exemptions extend tournament’s support of Farmers Insurance and APGA Tour’s efforts to grow diversity in golf
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The longer open enrollment period does give people some extra wiggle room during the busy holiday season. But for most people, December 15 is still the soft deadline you’re going to want to keep in mind. In most states, that’s the last day you can enroll in coverage that will take effect January 1.
Which states have open enrollment dates past December 15 – but still have January 1 effective dates?
There are some exceptions, however. The following state-run exchanges are giving people extra time to sign up for a plan that takes effect January 1:
But in the rest of the country, you need to enroll by December 15 to have your plan start on January 1. And that’s important for several reasons.
1. Currently uninsured? Delaying your enrollment will mean no coverage in January.
If you’re not already enrolled in ACA-compliant coverage in 2021, the current open enrollment period is your chance to change that for 2022.
But if you wait until the last minute to enroll, you won’t have coverage in place when the new year begins. Instead, you’ll be waiting until February 1 — or March 1 – if you enroll at the last minute in a few states with longer enrollment windows.
2. Currently uninsured or enrolled in a non-marketplace plan? Delayed enrollment might mean missing out on free money.
If you considered marketplace coverage in the past and found it to be unaffordable, you might currently be uninsured or enrolled in a plan that isn’t regulated by the ACA. Or you might have opted to buy ACA-compliant coverage outside the exchange, if you weren’t eligible for premium tax credits (subsidies) the last time you looked.
But thanks to the American Rescue Plan, many people who weren’t eligible for subsidies in previous years will find that they are now. Those subsidies are only available if you’re enrolled in a marketplace/exchange plan, and the current open enrollment period is your chance to make the switch to a marketplace plan.
In addition to being more widely available, premium subsidies are also larger than they were last fall. People who didn’t enroll last year due to the cost may find that coverage now fits in their budget.
Waiting until the last minute to enroll in coverage will mean that you leave all that money on the table for January. You can use our subsidy calculator to get an idea of how much your subsidy will be for 2022. Then, make sure you enroll by December 15 so that you’re eligible to claim the subsidy for all 12 months of the year.
3. Letting your plan auto-renew? You might be in for a surprise.
If you already have coverage through the marketplace in 2021 and are planning to just let it auto-renew for 2021, you might wake up on January 1 with coverage and a premium that aren’t what you expected.
Even if you’re 100% happy with the plan you have now, you owe it to yourself to spend at least a little time checking out the available options before December 15. The premium that your insurer charges is likely changing for 2022. And your subsidy amount might also be changing, especially if there are new insurers joining the marketplace in your area.
Your insurer might also be making changes to your benefits, provider network, or covered drug list — or even discontinuing the plan altogether and replacing it with a new one. In short, the plan and price you have on January 1 might be quite different from what you have now.
This is part of the reason HHS opted to extend the open enrollment period – in order to give people a chance for a “do-over” if their auto-renewed plan isn’t what they expected. In nearly every state, you’ll have until at least January 15 to pick a new plan. But that plan selection won’t be retroactive to January 1.
4. Out-of-pocket expenses won’t transfer in February or March.
What if you’re enrolled in a marketplace plan in 2021, let it auto-renew for 2022, and then decide after December 15 that you’d rather have a different plan? Thanks to the extended open enrollment period, you can do that, and your new plan will take effect in February (or potentially March, if you’re in one of the state-run exchanges with the latest enrollment deadlines).
But it’s important to understand that you’ll be starting over with a new plan in February or March. This means the out-of-pocket costs counted against your deductible and out-of-pocket maximum will reset to $0, even if you ended up with out-of-pocket expenses in January.
Out-of-pocket expenses reset to $0 on January 1 for all marketplace plans, so your auto-renewed policy will start over with a new deductible at that point. But if you need medical care in January (and have associated out-of-pocket costs) before your new plan takes effect in February, you’ll potentially have a higher out-of-pocket exposure for the whole year than you would have if you’d picked your new plan by December 15 and had it start January 1.
All of this is a reminder that while most enrollees have until at least mid-January to sign up for 2022 coverage, it’s in your best interest to get your plan selection sorted out by December 15.
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.
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With RV popularity on the rise and many road-trippers getting in their last journeys, Farmers Insurance® reminds drivers of seasonal hazards and the importance of regular maintenance
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For millions of Americans, the open enrollment period (OEP) to shop for 2022 ACA-compliant coverage will be unlike any of the previous eight OEPs. The reason? These consumers will – for the first time – be able to tap into the Affordable Care Act’s premium tax credits (more commonly referred to as health insurance subsidies).
Thanks to the American Rescue Plan, consumers who in previous years might have found themselves outside the eligible level for subsidies – or who may have found that subsidy amounts were so low as to not be enticing – are now among those eligible for premium tax credits. So if you haven’t shopped for health insurance lately, you might be surprised to see how affordable your health coverage options are this fall (starting November 1), and how many plan options are available in your area.
But there are still millions of others who are either uninsured or have obtained coverage elsewhere. And there are also people who already had coverage in the exchange in 2021 but didn’t take the option to switch to a more robust plan after the ARP was implemented. If you’re in either of these categories, you don’t want to miss the open enrollment period in the fall of 2021.
The Build Back Better Act, which is still under consideration in Congress, would extend the ARP’s subsidies and ensure that health insurance stays affordable in 2023 and beyond. But even without any new legislative action, most of the ARP’s subsidy enhancements will remain in place for 2022.
Who should make a point to review their subsidy eligibility?
So who needs to pay close attention this fall, during open enrollment? In reality, anyone who doesn’t have access to Medicare, Medicaid, or an employer-sponsored health plan – because even if you’re already enrolled and happy with the plan you have, auto-renewal is not in your best interest.
But there are several groups of people who really need to shop for coverage this fall. Let’s take a look at what each of these groups can expect, and why you shouldn’t let open enrollment pass you by if you’re in one of these categories:
1. The uninsured – eligible for low-cost or NO-cost coverage
The majority of uninsured Americans cite the cost of coverage as the reason they don’t have health insurance. Yet millions of those individuals are eligible for free or very low-cost health coverage but haven’t yet enrolled. This has been the case in prior years as well, but premium-free or very low-cost health plans are even more widely available as a result of the ARP.
If you’re uninsured because you don’t think health insurance is affordable, know that more than a third of the people who enrolled via HealthCare.gov during the COVID/ARP special enrollment period this year purchased plans for less than $10/month.
Even if you’ve checked in previous years and couldn’t afford the plans that were available, you’ll want to check again this fall, since the subsidy rules have changed since last year.
2. Consumers enrolled in non-ACA-compliant plans
There are millions of Americans who have purchased health coverage that isn’t compliant with the ACA. Most of these plans are either less robust than ACA-compliant plans, or use medical underwriting, or both. They include:
People purchase or keep these plans for a variety of reasons. But chief among them has long been the fact that ACA-compliant coverage was unaffordable – or was assumed to be unaffordable.
There are also people who prefer some of the benefits that some of these plans offer (the fellowship of being part of a health care sharing ministry, for instance, or the abundantly available primary care with a DPC membership). But by and large, the reason people choose coverage that isn’t ACA-compliant, or that isn’t even insurance at all, is because ACA-compliant coverage doesn’t fit in their budgets.
This has long included a few main groups of people: Those who earned too much to qualify for subsidies, those affected by the “family glitch,” and those who qualified for only minimal subsidy assistance and still felt that the coverage available in the exchange wasn’t affordable.
(Another group of people unable to afford coverage are those who earn less than the poverty level in 11 states that have refused to expand Medicaid and thus have a coverage gap. Some people in the coverage gap purchase non-ACA-compliant coverage, but this population is also likely to not have any coverage at all. If you or a loved one are in the coverage gap, we encourage you to read this article.)
The ARP has not fixed the family glitch or the coverage gap, although there are legislative and administrative solutions under consideration for each of these.
But the ARP has addressed the other two issues, and those provisions remain in place for 2022. The income cap for subsidy eligibility has been eliminated, which means that some applicants can qualify for subsidies with income far above 400% of the poverty level. And for those who were already eligible for subsidies, the subsidy amounts are larger than they used to be, making coverage more affordable.
So if you are enrolled in any sort of self-purchased health plan that isn’t compliant with the ACA, you owe it to yourself to check your on-exchange options this fall, during the open enrollment period. Keep in mind that you can do that through the exchange, through an enhanced direct enrollment entity, or with the assistance of a health insurance broker.
3. Buyers enrolled in off-exchange health plans
There are also people who have “off-exchange” ACA-compliant plans that they’ve purchased directly from an insurance company, without using the exchange. (Note that this is not the same thing as enrolling in an on-exchange plans through an enhanced direct enrollment entity, many of which are insurance companies).
There are a variety of reasons people have chosen to enroll in off-exchange health plans over the last several years. And for some of those enrollees, 2022 might be the year to switch to an on-exchange plan.
Since 2018, some people have opted for off-exchange plans if they weren’t eligible for premium subsidies and wanted to enroll in a Silver-level plan. This was a very rational choice, encouraged by state insurance commissioners and marketplaces alike. But if you’ve been buying off-exchange coverage in order to get a Silver plan with a lower price tag, the primary point to keep in mind for 2022 is that you might find that you’re now eligible for premium subsidies.
Just like the people described above, who have enrolled in various non-ACA-compliant plans in an effort to obtain affordable coverage, the elimination of the income limit for subsidy eligibility is a game changer for people who were buying off-exchange coverage to get a lower price on a Silver plan.
Some people have opted for off-exchange coverage because their preferred health insurer wasn’t participating in the exchange in their area. This might have been a deciding factor for an applicant who was only eligible for a very small subsidy — or no subsidy at all — and was willing to pay full price for an off-exchange plan from the insurer of their choice.
But 2022 is the fourth year in a row with increasing insurer participation in the exchanges, and some big-name insurers are joining or rejoining the exchanges in quite a few states. So if you haven’t checked your on-exchange options in a while, this fall is definitely the time to do so. You might be surprised to see how many options you have, and again, how affordable they are.
4. Consumers enrolled in on-exchange plans, but no income details on file and no recent coverage reconsiderations
But if the exchange didn’t have an income on file for you, they wouldn’t have been able to activate a subsidy on your behalf (on the HealthCare.gov platform, subsidy amounts were automatically updated in September for people who hadn’t updated their accounts by that point, but only if you had provided a projected income to the exchange when you enrolled in coverage for 2021). And even if your subsidy amount did get updated, you might have remained on the plan you had picked last fall, despite the option to pick a different one after the ARP was enacted.
The good news is that you’ll be able to claim your full premium tax credit, for the entirety of 2021, when you file your 2021 tax return (assuming you had on-exchange health coverage throughout the year). And during the open enrollment period for 2022 coverage, you can provide income information to the exchange so that a subsidy is paid on your behalf each month next year.
Reconsidering your plan choice during open enrollment might end up being beneficial as well. If you didn’t qualify for a subsidy in the past, or if you only qualified for a modest subsidy, you might have picked a Bronze plan or even a catastrophic plan, in an effort to keep your monthly premiums affordable.
But with the ARP in place, you might find that you can afford a more robust health plan. And if your income doesn’t exceed 250% of the poverty level (and especially if it doesn’t exceed 200% of the poverty level), pay close attention to the available Silver plans. The larger subsidies may make it possible for you to afford a Silver plan with built-in cost-sharing reductions that significantly reduce out-of-pocket costs.
One other point to keep in mind: If you are receiving a premium subsidy this year, be aware that it might change next year due to a new insurer entering the market in your area and offering lower-priced plans. Here’s more about how this works, and what to consider as you’re shopping for coverage this fall.
The takeaway point here? Even if you’ve been happy with your plan, you should check your options during open enrollment. This is not the year to let your plan auto-renew. Be sure you’ve provided the exchange with an updated income projection for 2022, and actively compare the plans that are available to you. It’s possible that a plan with better coverage or a broader provider network might be affordable to you for 2022, even if it was financially out of reach when you checked last fall.
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.
Effective through 2022 and likely to be made permanent by pending legislation, the ARP improvements to affordability were as follows:
A benchmark Silver plan (the second least expensive Silver plan) with strong cost sharing reduction (CSR) subsidies became free to enrollees with household income up to 150% of the Federal Poverty Level (FPL) and costs no more than 2% of income for enrollees with income up to 200% FPL. That’s a maximum of $43 per month for a single person with an income of $25,520.
The previous income cap on subsidy eligibility was removed, so that no one who lacks access to affordable coverage elsewhere (i.e., from an employer) has to pay more than 8.5% of income for a benchmark Silver plan (less at lower incomes). The eliminated cap was 400% FPL ($51,040 for an individual, $104,880 for a family of four), and some households with income well above that level now qualify for subsidies.
Anyone who received any unemployment insurance income during 2021 was eligible for free high-CSR Silver coverage. (Note that the pending legislation calls for this subsidy enhancement to be extended by several years, but not necessarily made permanent.)
Our 2022 Open Enrollment Guide: Everything you need to know to enroll in an affordable individual-market health plan.
ARP prompted an enrollment surge during the 2021 SEP
The enhanced subsidies were posted on HealthCare.gov on April 1, and in the state-run exchanges within a few weeks of that date. Existing enrollees were encouraged to update their information and get the new subsidies credited, and were allowed to switch plans if they chose.
Americans responded with a major surge in new enrollment and enrollment upgrades. From February 15 through August 15:
More than 2.8 million people enrolled in new health coverage. Of new enrollees, 91% qualified for premium subsidies.
Of new enrollees, 44% obtained coverage for less than $10 per month. Most of these enrollees (41% in HealthCare.gov states) received free coverage with the highest level of CSR. As a result, the median deductible fell from $750 in 2020 to $50 this year – meaning that half of enrollees obtained a plan with a deductible at or below that level (most of them in high-CSR Silver plans).
The average premium paid by new consumers during the SEP (Feb. 15 – Aug. 15) fell 30%, from $117 in 2020 to $81 in 2021.
Marketplace enrollment in August 2021, at 12.2 million, was 15% higher than in August 2020, the previous August high, and 22% above the pre-pandemic August high (see p. 14 here) recorded in 2016.
More than 200,000 new and existing enrollees qualified for free high-CSR Silver plans because they had received unemployment insurance income in 2021.
Savings were also dramatic for existing marketplace enrollees:
8 million existing enrollees reduced the premiums on their existing plans or obtained new plans after ARP implementation.
Existing enrollees reduced their premiums by 50%, or by $67 per month, on average.
My premium went down how much?
To get a sense of the extent to which the ARP reduced enrollee costs (or encouraged people who might previously have considered coverage too expensive to enroll), consider these examples:
In November 2020, a 40-year-old in Miami with an income of $24,000 per year would have paid $115 per month for the least expensive available Silver plan, with a $1,500 deductible, and $119 per month for the second-cheapest Silver plan, with a $0 deductible. Thanks to the ARP, those plans would now cost this person $26 and $30 per month, respectively.
In November 2020, a pair of 60-year-olds in Dallas, Texas with an income of $70,000 – slightly over the income cap for premium subsidies, which the ARP eliminated – would have had to pay $1,669 per month for the lowest cost Gold plan, with a $2,300 deductible (Gold plans are cheaper than Silver Plans in Dallas), or $1,228 for the lowest cost Bronze plan, with an $8,550 deductible.
Now, this couple can choose to pay $393 per month for the Gold plan (which includes free doctor visits and generic drug prescriptions, neither subject to the deductible), or consider two free Bronze plans with deductibles over $8,000, a $2/month Bronze plan with a $6,100 deductible, and other options. A BlueCross Silver plan available for $420 per month might also be in the mix, if, say, the provider network is preferable.
Which states saw the biggest gains in new enrollees?
The new enrollment surge – and the savings – was particularly strong in twelve states that had not enacted the ACA Medicaid expansion as of June 2021. Due to their failure to expand Medicaid, these states have a “coverage gap” for people who earn too little to qualify for marketplace coverage (less than 100% FPL, or $12,760 for an individual in 2021) but mostly also don’t qualify for Medicaid because of their states’ restrictive Medicaid eligibility. (That excludes Wisconsin, which has not enacted the ACA expansion but grants Medicaid eligibility to adults with income up to 100% FPL. Oklahoma, which expanded Medicaid beginning in July 2021, and Missouri, which will begin covering new Medicaid expansion enrollees in October, are included.)
These twelve states – Alabama, Florida, Georgia, Kansas, Missouri, Mississippi, North Carolina, Oklahoma, South Carolina, South Dakota, Tennessee, Texas and Wyoming – accounted for 1.55 million new enrollees during the SEP, or 55% of all new enrollees nationally.
In the non-expansion states, eligibility for marketplace subsidies begins at 100% FPL, as opposed to 138% FPL in Medicaid expansion states, where adults below that threshold qualify for Medicaid. Accordingly, in these states, about half of enrollees qualified for free high-CSR coverage, reporting incomes between 100% and 150% FPL. In these states, enrollment as of August 2021 (6.0 million) was 44% above enrollment in August 2019, the last pre-pandemic year (4.2 million).
More than 2 million people in non-expansion states are estimated to be stuck in the coverage gap – ineligible both for Medicaid and for ACA premium subsidies. For people in these states, reporting an income just below or just above 100% FPL ($12,760 for an individual, $26,200 for a family of four) is the difference between receiving no help at all and having access to free Silver coverage with high CSR and low out-of-pocket costs.
It’s important to keep in mind that the application for marketplace coverage requires an income estimate – and many people, unaware of the minimum income requirement, underestimate their potential income. For tips on how to make sure you leave no stone unturned in seeking help paying for coverage, see this post.
What do these numbers mean for 2022 open enrollment?
As open enrollment for 2022 approaches (it begins on November 1), the subsidies enhanced by the ARP remain in place for 2022. As Congress hashes out new investments for coming years in a pending budget bill, the pressure is intense to keep this good thing going in future years.
As of now, with the sad exception of those stuck in the coverage gap in states that still refuse to enact the ACA Medicaid expansion, any citizen or legally present noncitizen who lacks access to other forms of affordable coverage should be able to find it in the marketplace. If you need coverage, make sure to check out your options on HealthCare.gov or your state exchange.
The word that ACA marketplace plans are more affordable than ever has not yet reached many of the people who need coverage and qualify for premium subsidies. The Kaiser Family Foundation estimated in May that nearly 11 million uninsured people were subsidy-eligible. ACA enrollment assisters consistently report that many people who are eligible for coverage have no idea what’s on offer.
The Biden administration is trying to change that: after years of radical cuts in federal funds for enrollment assistance, the administration this year has allocated a record $80 million to fund nonprofit enrollment “navigator” groups charged with outreach as well as enrollment assistance. The Urban Institute forecast that if the ARP subsidies are made permanent – solidifying the perception that truly affordable coverage is here to stay — enrollment would increase by more than 5 million in 2022.
The emergency SEP provided a jump start, boosting coverage as of August more than 1.5 million above the August 2020 level. In a fraught and complex legislative session, Congress will most likely – though not certainly – do its part and extend the subsidies beyond 2022. There is certainly room for enrollment to run higher in the open enrollment season that begins on November 1.
Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid.His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic, and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D. in English literature from the University of Rochester.
Boston Dynamics Spot® Builds on Farmers® Commitment to Employee Safety & Customer-Centric Innovation
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$5,000 donation helps bolster Hawaii’s only pediatric critical care transport service
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A major premise of the Affordable Care Act (ACA) was that Americans who need to buy their own health coverage in the individual market should be able to obtain coverage – regardless of their medical history – and that the monthly premiums should be affordable.
The rules to facilitate those goals have been in place for several years now. And although they have worked quite well for some Americans, there have been others for whom ACA-compliant health coverage was still unaffordable.
How much are consumers saving on health insurance premiums?
And the amount that people are paying for their coverage and care is quite a bit lower than it was before the APR’s subsidy enhancements. We can see this across the states that use the federally run exchange (HealthCare.gov), as well as the states that run their own exchanges:
Among the people who enrolled during the recent special enrollment period in the 36 states that use HealthCare.gov, average after-subsidy premiums were 27% lower than the amounts people were paying pre-ARP.
Among HealthCare.gov enrollees who signed up during the special enrollment period or who updated their enrollments to claim the enhanced subsidies, 35% are now paying less than $10/month for their coverage.
The state-run exchange in Washington reported that 78% of their enrollees are now receiving premium subsidies, versus 61% before the ARP was implemented. And consumers with income above 400% of the poverty level, who were not eligible for subsidies pre-ARP, are now paying an average of $200 less in premiums each month. Washington’s exchange also noted that 15% of their enrollees are now paying $1/month or less for their coverage, versus only 5% whose premiums were that low pre-ARP.
The state-run exchange in California reported that consumers with household incomes between 400% and 600% of the poverty level are saving an average of almost $800/month on their premiums. (That’s an individual with income up to about $76,000, or a household of four with an income up to about $157,000.)
The state-run exchange in Nevada reported that people who enrolled or updated their account since the ARP was implemented are paying an average of $154/month in after-subsidy premiums, whereas the after after-subsidy premium at the end of last winter’s open enrollment period (pre-ARP) was $232/month.
Maryland’s state-run exchange reported a 12% increase in the number of enrollees receiving subsidies; more than 80% of Maryland’s current exchange enrollees are subsidy-eligible.
These examples highlight the improved affordability that the ARP has brought to the health insurance marketplaces. People who were already eligible for subsidies are now eligible for larger subsidies. And many of the people who were previously ineligible for subsidies — but potentially facing very unaffordable health insurance premiums — are benefiting from the ARP’s elimination of the income cap for subsidy eligibility.
This means that the affordability gains we’ve seen this year will be available during the upcoming open enrollment period, when people are comparing their plan options for 2022.
Even catastrophic plans – which are ACA-compliant but not compatible with premium subsidies – are likely to see reduced enrollment over the next year, since more people are eligible for enhanced subsidies that make metal-level plans more affordable.
Can everyone find affordable health insurance now?
Unfortunately, not yet. There are still affordability challenges facing some Americans who need to obtain their own health coverage. That includes more than two million people caught in the “coverage gap” in 11 states that have refused to expand eligibility for Medicaid, as well as about 5 million people affected by the ACA’s “family glitch.”
Families affected by the family glitch have access to an employer-sponsored plan that’s affordable for the employee but not for the whole family – and yet the family is also ineligible for subsidies in the marketplace/exchange. (It’s possible that the Biden administration could tackle this issue administratively in future rulemaking.)
Have ARP’s subsidy boosts been successful?
With the exception of those two obstacles, the ARP has succeeded in making affordable health coverage a more realistic option for most Americans who need to obtain their own health coverage. We can see success in the record-high exchange enrollment, the increased percentage of enrollees who are subsidy-eligible, and the reduction in after-subsidy premiums that people are paying.
If you’re currently uninsured or covered by a non-ACA-compliant plan (including a grandfathered or grandmothered plan), it’s in your best interest to take a moment to see what your options are in the ACA-compliant market. Open enrollment for 2022 coverage starts in just two months, but you may also find that you can still enroll in a plan for the rest of 2021 if you live in a state where a COVID/American Rescue Plan enrollment window is ongoing, or if you’ve experienced a qualifying event recently (examples include loss of employer-sponsored insurance, marriage, or the birth or adoption of a child).
Even if you shopped just last winter, during open enrollment for 2021 plans, you might be surprised at the difference between the premiums you would have paid then and now. The ARP wasn’t yet in effect during the last open enrollment period, so if you weren’t eligible for a subsidy last time you looked, or if the plans still seemed too expensive even with a subsidy, you’ll want to check again this fall.
The subsidies for 2022 will continue to be larger and more widely available than they’ve been in the past, and you owe it to yourself to see what’s available in your area.
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.
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State-of-the-art Mobile Claims Center (MCC) arrives in Baton Rouge to help customers with claims, and also offer telephone and internet access to residents in need
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Three fall events further strengthen Farmers® support of diversity-focused Advocates Pro Golf Association Tour
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The insurer is closely monitoring weather systems as Hurricane Ida appears to strengthen prior to a projected landfall in Louisiana
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Most Americans under the age of 65 get their health insurance from an employer. This makes life fairly simple as long as you have a job that provides solid health benefits: All you need to do is enroll when you’re eligible, and if your employer offers a few options from which to choose, pick the one that best fits your needs each year during your employer’s annual enrollment period.
But the downside to having health insurance linked to employment is that losing your job will also mean losing your health insurance, adding stress to an already stressful situation.
The good news is that you’ve got options — probably several, depending on the circumstances. Let’s take a look at what you need to know about health insurance if you’ve lost your job and are facing the loss of your employer-sponsored health coverage.
Can I enroll in self-purchased insurance as soon as I’ve lost my job?
If you’re losing your job-based health insurance, you do not have to wait for the fall open enrollment period to sign up for a new ACA-compliant plan.
If you enroll prior to your coverage loss, your new plan will take effect the first of the month after your old plan ends, which means you’ll have seamless coverage if your old plan is ending on the last day of the month.
Your special enrollment period also continues for 60 days after your coverage loss, although you’d have a gap in coverage if you wait and enroll after your old plan ends, since your new plan wouldn’t take effect retroactively.
If you’re in that situation, you might find that a short-term health plan is a good option for bridging the gap until your new plan takes effect. Short-term plans won’t cover pre-existing conditions and are not regulated by the Affordable Care Act (ACA). But they can provide fairly good coverage for unexpected medical needs during a temporary window when you’d otherwise be uninsured.
Be sure to check your options again during open enrollment
If you sign up for coverage now in your special enrollment period, keep in mind that you’ll still need to re-evaluate your coverage during the upcoming open enrollment period, which begins November 1. Even though you’re enrolling fairly late in 2021, your new plan will reset on January 1, with new pricing and possibly some coverage changes. There also might be new plans available in your area for 2022.
So your special enrollment period (tied to your coverage loss) will be your opportunity to find the best plan to fit your needs for the rest of this year. And if you’re still going to need self-purchased coverage in 2022, the upcoming open enrollment period will give you a chance to make sure you optimize your coverage for next year as well.
COBRA (or state continuation) versus self-purchased coverage
Depending on the size of your employer, COBRA might be offered to you. And even if your employer is too small for COBRA, you might have access to state continuation (“mini-COBRA”), depending on where you live. Either of these options will allow you to temporarily continue the coverage you already have, instead of switching to a new individual-market plan right away.
If COBRA or state continuation is available, your employer will notify you and give you information about what you’ll need to do to activate the coverage continuation and how long you can keep it.
Normally, you have to pay the full cost of COBRA or state continuation coverage, including the portion that your employer previously paid on your behalf — which was likely the bulk of the premiums. But until the end of September 2021 (so for just one more month), as part of the American Rescue Plan (ARP), the federal government will pay the full cost of COBRA or state continuation coverage for people who involuntarily lost their jobs.
For much of this year, the soon-to-end COBRA subsidy has changed the calculus that normally goes into the decision of whether to continue an employer-sponsored plan or switch to a self-purchased individual/family plan. But after the end of September, the normal decision-making process will again apply. And you’ll have a special enrollment period when the COBRA subsidy ends, which will allow you to transition to an individual/family plan at that point if you want to.
COBRA coverage vs individual-market health insurance
Here’s what to keep in mind when you’re deciding between COBRA and an individual-market health plan – either initially, or after the COBRA subsidy ends on September 30:
ACA marketplace subsidies are now available at all income levels, depending on the cost of coverage in your area (the American Rescue Plan eliminated the income cap for subsidy eligibility for 2021 and 2022). And the subsidies are substantial, covering the majority of the premium cost for the majority of marketplace enrollees. Unless your employer is continuing to subsidize your COBRA coverage after the federal subsidy expires, you’ll probably find that the monthly premiums are lower if you enroll in a plan through the marketplace, as opposed to continuing your employer-sponsored plan.
Have you already spent a significant amount of money on out-of-pocket costs under your employer-sponsored plan this year? You’ll almost certainly be starting over at $0 if you switch to an individual/family plan, even if it’s offered by the same insurer that provides your employer-sponsored coverage. Depending on the specifics of your situation, the money you’ve already paid for out-of-pocket medical expenses this year could offset the lower premiums you’re likely to see in the marketplace.
Do you have certain doctors or medical facilities you need to continue to use? You’ll want to carefully check the provider networks of the available individual/family plans to see if they’re in-network. And if there are specific medications that you need, you’ll want to be sure they’re on the formularies of the plans you’re considering.
Will you qualify for a premium subsidy if you switch to an individual/family plan? If you do qualify, you’ll need to shop in your exchange/marketplace, as subsidies are not available if you buy your plan directly from an insurance company. (You can call the number at the top of this page to be connected with a broker who can help you enroll in a plan through the exchange.) And again, as a result of the ARP, subsidies are larger and more widely available than usual; that will continue to be the case throughout 2022 as well.
Free health insurance if you collected unemployment in 2021
If you’re approved for even one week of unemployment compensation in 2021, you qualify for a premium subsidy that will fully cover the cost of the two lowest-cost Silver plans in the marketplace/exchange in your area, through the end of the year.
In addition to the subsidy that will allow you to get a free Silver plan, it will also ensure that any of the available Silver plans have full cost-sharing reductions.
What if my income is too low for subsidies?
In order to qualify for premium subsidies for a plan purchased in the marketplace, you must not be eligible for Medicaid, Medicare, or an employer-sponsored plan, and your income has to be at least 100% of the federal poverty level. (As noted above, for 2021 only, you’re eligible for subsidies if you receive unemployment compensation, regardless of your actual total income for the year, as long as you’re not eligible for Medicaid, Medicare, or an employer’s plan.)
In most states, the ACA’s expansion of Medicaid eligibility provides coverage to adults with household income up to 138% of the poverty level, with eligibility determined based on current monthly income. So if your income has suddenly dropped to $0, you’ll likely be eligible for Medicaid and could transition to Medicaid when your job-based coverage ends.
Unfortunately, there are still 11 states where most adults face a coverage gap if their household income is below the federal poverty level. They aren’t eligible for premium subsidies in the marketplace (unless they’ve received unemployment compensation in 2021 and can thus qualify for 2021 subsidies).
And keep in mind that subsidy eligibility in the marketplace is based on your household income for the whole year, even if your current monthly income is below the poverty level. So if you earned enough earlier in the year to be subsidy-eligible for 2021, you can enroll in a plan with subsidies based on that income, despite the fact that you might not earn anything else for the rest of the year.
When open enrollment begins in November, you’ll need to project your 2022 income as accurately as possible, if you’re still needing to purchase your own coverage for 2022. But for the rest of 2021, you can use the income you already earned this year to qualify for subsidies.
What if I’ll soon be eligible for Medicare?
There has been an increase recently in the number of people retiring in their late 50s or early 60s, before they’re eligible for Medicare. The ACA made this a more realistic option starting in 2014, thanks to premium subsidies and the elimination of medical underwriting.
And the ARP has boosted subsidies and made them more widely available for 2021 and 2022, making affordable coverage more accessible for early retirees. That’s especially true for those whose pre-retirement income might have made them ineligible for subsidies in the year they retired, due to the “subsidy cliff” (which has been eliminated by the ARP through the end of 2022).
So if you’re losing your job or choosing to leave it and you still have a few months or a few years before you’ll be 65 and eligible for Medicare, rest assured that you won’t have to go uninsured.
You’ll be able to sign up for a marketplace plan during your special enrollment period triggered by the loss of your employer-sponsored plan. And even if you earned a fairly robust income in the earlier part of the year, you might still qualify for premium subsidies to offset some of the cost of your new plan for the rest of 2021.
You’ll then be able to update your projected income for 2022 during the upcoming open enrollment period; your subsidies will adjust in January to reflect your 2022 income.
And marketplace plans are always purchased on a month-to-month basis, so you’ll be able to cancel your coverage when you eventually transition to Medicare, regardless of when that happens.
Don’t worry, get covered
The short story on all of this? Coverage is available, and obtaining your own health plan isn’t as complicated as it might seem at first glance, even if you’ve had employer-sponsored coverage all your life.
You can sign up outside of open enrollment if you’re losing your job-based insurance, and there’s a good chance you’ll qualify for financial assistance that will make your new plan affordable.
You can learn more about the marketplace in your state and the available plan options by selecting your state on this map. And there are zero-cost enrollment assisters – Navigators and brokers – available throughout the country to help you make sense of it all.
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.
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Farmers® expands its commitment to help grow diversity in the game of golf through new relationship with the BCGCA focused on supporting and developing college and amateur athletes
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The American Rescue Plan’s enhancements to the Affordable Care Act’s health insurance subsidies will continue long after the end of the COVID SEP. That means that when you do have an opportunity to buy coverage again – either through open enrollment or due to a personal qualifying life event – you’ll likely find individual health insurance much less expensive than you might have expected.
The ARP’s affordability provisions are still helping with premiums
As we’ve noted over the past few months, the American Rescue Plan included numerous provisions that make ACA-compliant plans more affordable than ever. The additional health insurance subsidy enhancements delivered by the ARP include:
All of those benefits continue to be available. The additional subsidies based on unemployment compensation continue through the end of 2021, while the other subsidy enhancements will be available through the end of 2022 (and possibly longer, if Congress extends them).
How popular are the ARP’s subsidy enhancements?
HHS reported last week that more than 2.5 million people had already enrolled in coverage during the COVID-related special enrollment period, and that another 2.6 million existing marketplace enrollees had activated their ARP subsidies.
Among all of the new enrollees, average after-subsidy premiums were just $85/month, as opposed to $117/month before the ARP’s subsidies became available. And across all of the new and renewing enrollees, about 35% had obtained coverage with after-subsidy premiums of less than $10/month.
That illustrates how substantial premium subsidies have become under the ARP. And again, nothing has changed about those subsidies: the special enrollment window has ended in most states, but the subsidies are still available if you’re eligible to enroll for the remainder of 2021 — and again during open enrollment for 2022, which starts November 1.
So if you’re in a state where enrollment is still open, or if you’re eligible for an individual special enrollment period in any state, it’s certainly in your best interest to see what plan options are available to you.
Enrolling as soon as you’re eligible will mean that you’re able to start taking advantage of the ARP’s subsidies right away, rather than having to wait for open enrollment and coverage that starts in 2022.
States where enrollment continues
Although the COVID SEP ended on August 15 in the states that use HealthCare.gov – and some of the states that run their own exchanges – enrollment is still actually ongoing in several states:
Vermont: Enrollment continues through October 1 (for uninsured residents).
Connecticut: General enrollment continues through October 31.
California: Enrollment continues through December 31 for uninsured residents and those switching from off-exchange to on-exchange coverage. There is also a temporary wildfire-related SEP in California, for residents in areas where a state of emergency has been declared due to wildfires.
New Jersey: General enrollment continues through December 31.
New York: General enrollment continues through December 31.
Enrollment if you have a qualifying life event
Not in one of those states? Special enrollment periods are available to individuals who experience a wide range of “life changes.” The most common trigger for a personal SEP is a loss of other coverage — usually job-based coverage.
(Note that there’s usually only a 60-day window to enroll in a new plan after losing other coverage. But HealthCare.gov is making an exception for people who lost their coverage as long ago as January 2020, if they missed their enrollment deadline because they were “impacted by the COVID-19 emergency.” People who need to utilize this flexibility have to call the marketplace directly to qualify for a special enrollment period on a case-by-case basis.)
More opportunities to enroll in ACA-compliant coverage
In addition to the states with ongoing COVID-related enrollment periods and the individual SEPs triggered by qualifying life events, there are other circumstances under which you might still be eligible to enroll in affordable health coverage:
If you’re eligible for Medicaid or CHIP in any state, enrollment continues year-round.
If you’re eligible for the Basic Health Programs in New York and Minnesota, you can enroll anytime.
If you don’t have an enrollment period now, be sure to mark your calendar for the start of open enrollment on November 1. That’s when you’ll be able to sign up for health coverage that will take effect in January, with coverage for essential health benefits and pre-existing conditions. During open enrollment, your medical history won’t matter, and neither will your coverage history.
And if you’re already enrolled in an ACA-compliant plan – or soon will be – you’ll still want to pay attention to open enrollment this fall. There are new insurers joining the marketplaces in many areas, which might have an unexpected effect on your premium subsidy. And even if you’re happy with the plan you have now, you might find that a different plan works better for the coming year.
Fortunately, the ARP’s subsidy enhancements will continue to be available for 2022. So if you’re eligible for subsidies – and most people are – your coverage for next year is likely to be quite affordable.
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.
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Recent news about individual-market health insurance has been largely centered around the American Rescue Plan and how it’s made coverage in 2021 much more affordable than it used to be. Now, as we approach ACA’s annual open enrollment period, it’s a good time to look ahead to what we can expect to happen with 2022 coverage.
Fortunately, the ARP’s enhanced subsidies will still be in effect in 2022 – and possibly longer, if Congress can agree on an extension. That means subsidies will continue to be larger than they used to be, and more widely available, including to households earning more than 400% of the poverty level.
For 2022 individual/family coverage, we’re seeing some wide variation in proposed and finalized rate changes across the country. Average rates will decrease in some areas and increase in others, with modest single-digit rate changes in most places.
Increased insurer participation in marketplaces continues
But we’re also seeing widespread continuation of the increasing insurer participation trend that’s been ongoing since 2019. In 2017 and 2018, insurers fled the ACA’s exchanges – or even the entire individual/family market. But that started to turn around in 2019, and insurer participation increased again in 2020 and 2021.
For 2022, that trend is continuing. Some big-name insurers that previously scaled back their marketplace participation are rejoining various marketplaces, and some smaller regional insurers are joining marketplaces or expanding their existing footprints.
Where are new carriers entering ACA’s marketplace for 2022?
Here’s a summary of some of the major individual/family insurers that are entering new markets for 2022:
US Health and Life is joining the marketplace in Indiana.
Hometown Health Plan is joining the marketplace in Nevada.
Innovation Health Plan is joining the marketplace in Virginia.
More carriers = more plan options …
That’s in addition to numerous coverage area expansions by existing marketplace insurers in many states. Based on the rate filings that we’ve analyzed thus far, we anticipate that many – if not most – marketplace enrollees will have more plan options available for 2022 than they had this year.
One of the goals of the ACA was to increase competition in the individual health insurance market. The exchanges are set up to facilitate that, with enrollees able to compare options from all of the participating insurers and select the plan that best fits their needs.
From that perspective, increasing insurer participation and competition in the exchange is good. And it does give people more plans from which to choose, which can also be a good thing. But too many choices can overwhelm applicants and result in poor decision making.
… and a new carrier could also affect premium subsidies
In addition to delivering more plan options, carriers expanding into an area might also affect premium subsidies in that area. How much effect will depend on how the new plans are priced in comparison with the existing plans – keeping in mind that rates change each year on January 1 regardless of whether any new insurers are entering the market.
Premium subsidy amounts are based on the cost of the benchmark plan in each area. But since that just refers to the second-lowest-cost Silver plan, it’s not necessarily the same plan from one year to the next. If a new insurer enters the market with low-priced plans, the insurer may undercut the current benchmark and take over the second-lowest-cost spot. If the premium is lower than the benchmark plan’s price would otherwise have been, the result is smaller premium subsidies for everyone in that area.
For people in that area who prefer to keep their existing plan (as opposed to switching to the new lower-cost options), this can result in an increase in after-subsidy premiums, since the subsidies are smaller than they would otherwise have been. We can see an example of this in the Phoenix area in 2019 and 2020, when new insurers entered the market with lower-priced plans that reduced the size of premium subsidies in the area.
To clarify, anything that reduces the cost of the benchmark premium will result in smaller subsidies. This can be a new lower-cost insurer entering the market, or existing insurers reducing their rates. An example of this can be seen in how after-subsidy premiums increased for many of Colorado’s exchange enrollees in 2020, when the state’s new reinsurance program reduced average pre-subsidy premiums by about 20%. The reduction helped unsubsidized enrollees (mostly those with incomes over the limit for subsidy eligibility, which has been removed at least through 2022) but resulted in higher net premiums for many enrollees who qualified for subsidies.
Although the vast majority of exchange enrollees do qualify for premium subsidies (especially now that the American Rescue Plan has eliminated the “subsidy cliff” for 2021 and 2022) some enrollees do not. For these enrollees, the introduction of a new insurer simply broadens their plan options, and does not affect their premiums unless they choose to switch to the new plan.
And of course, if the new insurer has plans that are priced higher than the existing benchmark plan, the carrier’s entry will not affect net premiums paid by subsidized enrollees.
Plan to compare your coverage options during open enrollment
It will be several weeks before all the details are clear in terms of rate changes and plan availability for 2022 coverage. But it appears that the trend of increasing competition in the exchanges will continue.
And although the American Rescue Plan’s enhanced subsidy structure will still be in place in 2022 – making subsidies larger and more widely available than they would otherwise have been – it’s still possible for a new insurer to disrupt the market and end up adjusting the size of premium subsidies in a given area.
Open enrollment for 2022 coverage will begin November 1. Actively comparing your options during open enrollment is always the best approach, and that’s especially true if a new insurer will be offering plans in your area. Letting your current plan auto-renew without comparison shopping is never in your best interest.
If a new insurer is joining the marketplace, you may find that its plans are a perfect fit for your needs. Or you might find that your best option is to switch to a different plan because your after-subsidy premiums are increasing due to the new insurer undercutting the price of the current benchmark plan. Switching plans might be a non-starter due to your provider network or drug formulary needs, but you won’t know for sure until you consider the various options that are available to you.
Ask a professional how a new carrier could impact your coverage
Brokers are licensed and regulated by state insurance departments, and must also have certification from the exchange in order to help people enroll in health plans offered through the exchange. Training and testing are necessary in order to obtain the license and certification, and brokers must also complete ongoing continuing education in order to maintain their credentials.
Broker training encompasses a wide range of topics, including ethics, fraud prevention, evolving insurance laws and regulations, and health plan details. The training and regulatory oversight make brokers a reliable source of information and assistance with initial plan selections and enrollments as well as future issues that might arise as the health plan is utilized.
Navigators should be much more widely available this fall, as the Biden administration has allocated $80 million for this year’s Navigator grants in the states that use HealthCare.gov. (The previous high was $63 million in 2016; the Trump administration subsequently reduced it to $36 million in 2017 and to $10 million each year from 2018 through 2020.) The Biden administration has also proposed a return to expanded duties for Navigators, which would provide consumers with increased access to post-enrollment assistance with their coverage.
In short, enrollment assistance should be widely available this fall, and it’s in your best interest to use it. A recent report from Young Invincibles highlights the myriad ways that enrollment assisters help consumers – it’s more than just picking a plan.
Regardless of where you seek assistance, it won’t cost you anything – and a broker, Navigator, or enrollment counselor will be able to help you determine the impact of any new insurers that will be offering plans in your area for 2022, and help you make sense of the options available to you.
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.
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In eleven of the twelve states that have so far refused to enact the Affordable Care Act’s expansion of Medicaid eligibility (which the Supreme Court made optional for states in 2012), there’s good news and bad news for people who are seeking health insurance for 2022 and don’t earn a lot of income.
The good news is that COVID-19 relief legislation signed by President Biden in March of this year, the American Rescue Plan Act, vastly improved subsidies in the ACA private plan marketplace. Comprehensive coverage – a Silver plan with strong cost-sharing reductions – is now free to many low-income Americans, and heavily subsidized for people who earn a bit more.
The bad news is that in states that have refused to enact the Medicaid expansion, the government still offers no help to people who report household incomes below the poverty line.
ACA’s coverage gap
The ACA’s creators intended for people in this income category to get Medicaid, but governors and legislators in the twelve “nonexpansion” states said no – even though the federal government foots 90% of the cost. More than 2 million low-income adults in these states are in the ACA’s coverage gap – eligible neither for Medicaid nor for help paying for coverage in the ACA private plan marketplace.
The minimum income to qualify for subsidized marketplace coverage in “nonexpansion” states is 100% of the federal poverty level (FPL). For enrollment in 2022, the cutoffs are as follows. (They are slightly lower for those still seeking coverage for the remainder of 2021.)
Persons in
family/household
100% FPL
(minimum to qualify for coverage)
1
$12,880
2
$17,420
3
$21,960
4
$26,500
A Silver plan with strong cost-sharing reduction is free to enrollees with incomes between 100% FPL and 150% FPL. (In 2022, that’s $19,230 for an individual, $39,750 for a family of four.) At 150-200% FPL, Silver coverage costs no more than 2% of income.
At incomes above 200% FPL, the percentage of income required for a benchmark Silver plan rises with income to a maximum of 8.5% of income. But again, in non-expansion states, subsidies are not available to people in households with incomes below 100% FPL.
Stumbling blind into the coverage gap
The application for coverage on HealthCare.gov – the federal marketplace for health coverage used by all of the non-expansion states (and 24 other states) – does not highlight the minimum income required for coverage. As a result, many low-income applicants who might expect to get federal aid find themselves confronted with a choice of plans quoted at full, unsubsidized cost – an average of $452 per month per adult for benchmark Silver coverage, unaffordable for almost all low-income enrollees.
Very few low-income enrollees know about the minimum income requirement, or know that their state legislatures and governors have denied them the Medicaid coverage that the ACA’s creators intended for them.
Many who work uncertain hours, or are self-employed, or do seasonal work, may not recognize how many variables go into their estimate of annual household income, which determines the size of subsidy – or whether a subsidy is available at all.
For applicants with incomes near the federal poverty line, knowing the stakes – that good coverage is free just above the 100% FPL threshold, and unaffordable just below that threshold – can make the difference between coverage and no coverage. For anyone not on a fixed salary, a good-faith estimate of next year’s income allows for some wiggle room. Many applicants may miss including allowable income sources, or fail to take fluctuations in their income into account, or otherwise miss the opportunity to claim a qualifying income.
A budget resolution introduced last week by Sen. Bernie Sanders proposes to create a new federal program that would offer insurance to people in this “coverage gap.” But with Democrats holding narrow majorities in both houses of Congress, their ability to create such a program is at best uncertain. Even if they do, it likely won’t go into effect in 2022.
Here is a checklist of strategies that may help you achieve eligibility for subsidized ACA coverage.
1. Know the eligibility cutoff. As noted above, to qualify for subsidized coverage, an applicant must estimate an annual income for the coming year that’s above 100% of the Federal Poverty Level ($12,880 for an individual, $17,420 for a couple, etc. in 2022. See the list above.) This point can’t be emphasized enough, according to Shelli Quenga, Director of Programs at the Palmetto Project, a nonprofit health insurance brokerage in South Carolina. “You need to know what amount you’re shooting for,” Quenga says. “You need to know where that line is. HealthCare.gov does not tell you.”
2. Use gross income, not net. Many applicants don’t recognize these terms, which denote income before and after taxes. Gross income, which the application requires, is basically the largest number on the pay stub or tax form.
3. Consider earning more income if necessary. When clients’ estimates fall short, Quenga will ask them what they can do to hit the target. “I’ll say, ‘Can you think of something you can do that’s going to earn you another $150 a month? Bake cakes? Clean houses? Mow grass? Do some babysitting? Provide some care to a nearby elderly person?’” Extra income of this sort can be entered on the application as self-employment, with wage income entered elsewhere.
4. Recognize uncertainty. The marketplace application for coverage provides a box to check “if you think your income will be difficult to predict.” That’s the case for many people – especially at low wages. If it’s hard to forecast how many hours you’ll work per week, how much you’ll make per hour (tips or overtime may make this variable), or how much work you’ll get if you’re self-employed, keep the eligibility threshold in mind as you estimate these factors.
5. Count everyone’s income. Household income includes income earned by everyone included in your tax return, including those who are not seeking coverage. Jennifer Chumbley Hogue, CEO of KG Health Insurance in Murphy Texas, cites the case of a woman in her early 60s whose husband is on Medicare and Social Security. “If your spouse is getting Social Security income, don’t forget to include it,” she says. That also holds for pensions, retirement accounts, and alimony (if awarded before 2019).
6. Consider how to count. The application allows you to estimate income on an hourly, weekly, twice-monthly, monthly or annual basis – and, if your income changes during the year, it invites you to estimate a different income for next year than for the current year. This flexibility allows you to take account of factors described below.
You can view the application on the HealthCare.gov site here. The income questions are on page 3. Note that the form recognizes the uncertainty involved in forecasting future income.
Considerations for individuals earning an hourly wage
If your income estimate is based on an hourly wage, consider the following questions:
Is the amount you and other workers in your household earned in the current month (or on the pay stubs you’re looking at) representative of what you are likely to earn throughout the year?
If you or a household member are a seasonal worker, have you fully accounted for that person’s likely full-year income?
Do you work more hours or earn more tips during the holiday season (or at other times of the year?) Have you fully accounted for that? Does anyone in the household take on a second job or temp job during the holiday season (or other season)? Have you included that income?
Do you sometimes get paid overtime? Do the pay stubs you’re using to estimate income reflect that?
Do you have reason to anticipate a raise in the coming year? (For example, Florida will raise the state minimum wage to $10 per hour in September 2021, and to $11 per hour in September 2022). If so, estimate your income on the basis of future pay rates.
Many who report income on an hourly wage basis work uneven and uncertain schedules. If a single person is unsure how many hours per week they’re likely to work, “I often tell them to put down 30 hours,” says Hogue – an amount that generally will qualify a solo applicant for coverage at an hourly wage of $8.50 or higher.
Strategies for the self-employed
Many of the low-income clients served by the Palmetto Project are self-employed, Quenga says. “Charleston is a huge destination wedding site. We have a lot of wedding planners, DJs, photographers, videographers.” Estimating next-year income is especially difficult if you’re self-employed, Quenga notes.
And for the self-employed, “Your projected income is your best guess of what you hope to earn.” She notes that the self-employed are generally oriented toward minimizing their income for tax purposes. For the health insurance application, they have to reverse that mindset.
Considerations when estimating your income for 2022
When you apply for coverage for 2022 (or the remainder of 2021), you may have your 2020 tax return to refer to, as well as well as pay stubs for at least 10 months’ income in 2021. If the totals for 2020 or 2021 are below the eligibility cutoff, that’s not necessarily going to be true in the year following. When estimating income in this case, consider these questions:
Were your hours cut because of the pandemic? Regardless, can you realistically expect to work more hours in 2022 (or the remainder of 2021)? These questions apply to everyone in your household – that is, all who file taxes together and earn any income. If so, you can estimate a higher income for the coming year in good faith.
Should you check off allowable tax deductions? The health insurance application asks about tax deductions that, if taken, reduce your gross income. The application points out that reporting these deductions “could make the cost of health coverage a little lower.” That’s true – if your income is above 150% FPL (Coverage is free up to that threshold.)
But if your income hovers near 100% FPL, these deductions could put your income below that threshold and disqualify you from subsidized coverage. The deductions listed on the application are those taken for interest paid on student loans, tuition and fees, retirement plan contributions, and alimony paid. If your income is near the cutoff, “do not check off a deduction that will put you under 100% FPL,” says Hogue.
If you were unemployed in any part of 2021 The American Rescue Plan provides free marketplace coverage in 2021 for any applicant who received any unemployment insurance income at any point in the year. After the emergency special enrollment period (SEP) ends on August 15, you will need to apply for a personal SEP to access this benefit – and do so within 60 days of having lost employer-sponsored coverage or experienced another qualifying life event. This particular benefit is not available in 2022.
What if your income estimate turns out to be higher than what you actually earn?
Low-income applicants may worry that they will owe large sums of money if their income estimate proves inaccurate. While those who underestimate their income do have to pay back a portion of their subsidy at tax time, that is not the case for those who overestimate income (in fact, if over-estimators pay any premium at all, they will get a partial refund).
If income for the year in question ultimately proves to fall below the 100% FPL threshold, there is no clawback of subsidies granted, unless the applicant’s income estimate is made with “intentional or reckless disregard for the facts.”
Your income estimate has to be good faith. You can’t make stuff up. But within the range of the realistically probable, you have leeway. “Suppose you mow grass for a living, and there was a drought,” Quenga posits. “You can’t control that. There is no penalty if you don’t end up hitting your target.”
Who’s checking your income anyway?
The ACA exchanges do check applicants’ income estimates against data sources such as employer records. In 2019, the Trump administration implemented a rule requiring the ACA exchanges to demand income documentation from applicants who claimed an income above 100% FPL if “trusted data sources” indicated an income below the threshold. If the enrollee failed to provide the documentation, the federal subsidy would be cut off, and the enrollee would likely lose coverage due to the unaffordability of the unsubsidized premiums.
But that rule was challenged in court, and in March 2021 a federal court ordered the Department of Health and Human Services (HHS) to rescind it. HHS responded promptly, rescinding the documentation requirement this past May. HHS did warn that its computer systems could not be retooled instantly, so that for some time, a request for income documentation would be sent in this situation. But HHS added that it would send a follow-up communication to the enrollee, saying that documentation was not required.
The ACA’s creators did not intend to shut poor Americans out of its benefits. But governors and state legislatures that refuse to enact the ACA Medicaid expansion do willfully perpetuate the coverage gap. Low-income people in non-expansion states should use every tool available to produce a good faith income estimate that will give them access to quality government-subsidized health insurance.
* * *
* States that enact the ACA Medicaid expansion offer Medicaid to all legally present adults with household incomes up to 138% FPL. Wisconsin, uniquely, offers Medicaid to adults with incomes up to 100% FPL – which is also the bottom threshold for subsidy eligibility in the private plan marketplace. No one, therefore, is excluded from aid on the basis of income.
Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid.His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic, and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D. in English literature from the University of Rochester.
https://www.maddoxinsured.com/wp-content/uploads/2021/08/income-changes.jpg2142171wpmaddoxinshttps://www.maddoxinsured.com/wp-content/uploads/2020/12/maddox-insurance-agency.pngwpmaddoxins2021-08-13 14:00:372021-08-13 15:00:28Six strategies for avoiding the Affordable Care Act’s coverage gap
Each year, HHS issues a set of rules and guidelines that apply to the health insurance exchanges created by the Affordable Care Act, and to the health plans that are sold in the individual/family market. The rule-making process includes a proposed rule, a public comment period, and then a final rule. This is normally a fairly straightforward process, but it’s been more complicated for the upcoming 2022 plan year.
The Trump administration issued the proposed 2022 rules in late November last year, and finalized some of them in January, just before inauguration day. In May, the Biden administration finalized the rest of the proposed rule changes, but noted that they intended to propose a new set of rules, with a new public comment period, in order to revisit some of the changes that had been finalized by the outgoing administration.
Some of the new proposals are direct reversals of the rule changes that the Trump administration had made. Others are new ideas that are designed to help more people gain access to affordable health insurance. For various provisions, HHS notes that there are pros and cons to the proposals they’re making, and are seeking public feedback before any rules are finalized.
As is always the case, some of the proposed rules are more “behind the scenes” and wouldn’t be particularly noticeable to consumers. But there are some that would directly affect consumers, mostly by making it easier to enroll in health coverage.
How about an extra month of open enrollment?
For the last several years, the standard open enrollment period has been set at November 1 – December 15. This is the schedule that’s used by HealthCare.gov (the exchange/marketplace in 36 states), although Washington, DC and 14 states run their own exchange platforms and most of them tend to extend open enrollment.
HHS has now proposed adding an extra month to open enrollment, so that it would continue through January 15 instead of ending in mid-December. If finalized, this rule change would take effect for the upcoming open enrollment period that starts in November, for coverage effective in 2022.
HHS clarifies that the intent here is to give people more time to enroll, and give enrollment assisters more time to help everyone who needs it. They also point out that some people don’t realize how much their premiums might change from one year to the next, and are caught off guard when they get their invoice in January. By that point, however, it’s normally too late to change plans, and people might end up dropping their coverage altogether if it’s become too expensive. By giving people until January 15 to enroll, there’s time for a “do-over” if a policy was allowed to auto-renew and then ended up being more expensive than expected.
On the other hand, HHS notes that when enrollment ends in mid-December, everyone has full-year coverage, with policies that take effect in January. If enrollment is extended until mid-January, some enrollees will have coverage that takes effect in February instead. Most of the state-run exchanges already offer this, but it would take additional outreach and communication to ensure that consumers are aware that they would still need to enroll by mid-December in order to have coverage in effect as of January 1.
Year-round enrollment for people with income up to 150% FPL
HHS has proposed an ongoing enrollment opportunity for applicants with household income that doesn’t exceed 150% of the federal poverty level. If finalized, this would allow eligible applicants to enroll in coverage at any time of the year. (Under current rules, enrollment outside of the normal open enrollment period requires a special enrollment period, triggered by a qualifying life event).
This enrollment opportunity would be offered through the federally run exchange (HealthCare.gov), and state-run exchanges would have the option to offer it. HHS has clarified that it’s uncertain whether this could be added as an option for the 2022 plan year. It might need to be delayed until 2023 to give health plan actuaries adequate time to prepare for this change.
The American Rescue Plan, enacted earlier this year, has enhanced the ACA’s premium tax credits (premium subsidies) for 2021 and 2022, providing more financial help for people who buy their own health insurance. As a result, households with income up to 150% of the federal poverty level are eligible for subsidies that fully cover the cost of the benchmark plan.
That means they can select either of the two lowest-cost Silver plans and have no monthly premium. (They will also tend to have access to a variety of premium-free Bronze plans, and possibly some premium-free Gold plans. But Silver plans are generally the best option for people in this income range, due to the robust cost-sharing reductions that come with Silver plans.)
HHS notes that the enhanced premium subsidies would help to prevent adverse selection, since most applicants with household income up to 150% of FPL would be able to enroll in Silver plans — with strong cost-sharing reductions — without premiums. This means that they would be unlikely to drop their coverage after receiving medical care, as they would not have to pay anything to keep the coverage in force. (This would be applicable for 2022, assuming the year-round enrollment option could be added for 2022. For 2023 and future years, the availability of zero-premium Silver plans will depend on whether Congress extends the American Rescue Plan’s subsidy enhancements.)
However, HHS does note that some enrollees with income up to 150% of FPL do have to pay at least minimal premiums for the benchmark plan. This includes people in states where additional services beyond essential health benefits are required to be covered (and thus the premium subsidy doesn’t cover the entire cost of the benchmark plan) as well as applicants who are subject to a tobacco surcharge.
And it’s also possible for a person earning up to 150% of FPL to purchase a Silver plan that’s more expensive than the benchmark plan, and thus have a monthly premium even after the subsidy is applied.
It’s possible that there could be some adverse selection among these populations, with enrollees potentially dropping their coverage or shifting to a lower-cost plan after their medical needs are resolved. HHS is seeking public comments about how to best approach this.
It’s worth noting that Medicaid and CHIP enrollment is already available year-round, as is Basic Health Program enrollment in the two states where it’s available. In most states, Medicaid is available to adults under age 65 with household income up to 138% of the poverty level. The income caps are higher for children to qualify for Medicaid, and CHIP is available to children (and in some cases, pregnant women) in many middle-class households.
So a family with low or modest income can obtain coverage year-round in most states — for the children, and possibly the adults. This is true even though many CHIP programs — and some Medicaid programs — charge premiums. Extending open enrollment to run year-round for subsidy-eligible applicants with household income up to 150% of the poverty level would essentially just be an expansion of the enrollment eligibility rules that already exist for lower-income households.
Including the ACA’s expansion of Medicaid, health insurance exchanges, and Basic Health Programs, ACA enrollment now encompasses about 10% of all Americans. But there are still millions of Americans — most of whom have fairly low incomes — who are uninsured and possibly unaware of the financial assistance that’s available to them. HHS is working to make coverage as accessible as possible to this population, and the proposed year-round enrollment window is part of that approach.
Standardized plans return to HealthCare.gov for 2023
Five years ago, HealthCare.gov debuted standardized health plans, dubbed “Simple Choice” plans. The idea was to make it easier for consumers to compare apples to apples when looking at multiple health insurance policy options.
The Trump administration finalized a rule change in 2018 that eliminated Simple Choice plans starting with the 2019 plan year. So HHS did not create standardized plan designs for the last few years.
The 2018 rule change that eliminated standardized plan designs on HealthCare.gov was vacated by a court ruling earlier this year, as were three other provisions of the 2018 rule. So HHS is starting the process of once again creating standardized plans and gathering public feedback on how to best proceed.
And earlier this month, President Biden issued a wide-ranging executive order aimed at promoting competition in the U.S. economy. One of its provisions calls for HHS to “implement standardized options in the national Health Insurance Marketplace and any other appropriate mechanisms to improve competition and consumer choice.”
When standardized plans were previously available in the federally run exchange, it was optional for insurers to offer them and insurers were also free to offer a variety of non-standardized plans. The specifics of their reintroduction are unclear at this point, but the proposed rules seem to indicate that the plans, which are expected to be available for the 2023 plan year, will continue to be optional for insurers.
Consumer protection rules
Some of the other proposed rule changes are designed to protect consumers, although their implementation might not be obvious.
Over the last few years, HHS had implemented several regulatory changes that would have eroded various consumer protections or created confusion in the marketplace. But these rules have either been blocked by the courts or had little in the way of interest from states. And now HHS has proposed a reversal of some of them:
Insurers are required to collect at least $1/month in premiums to cover the cost of non-Hyde abortion coverage if it’s offered by a health plan. Premium subsidies can’t cover this amount, and insurers must keep the funds segregated from the rest of the premiums they collect. But a previous rule change required insurers to actually send separate invoices for this amount. A judge blocked that rule last year before it took effect, noting that it would lead to widespread consumer confusion. And now HHS is proposing that the rule simply be eliminated altogether. Insurers would still have to segregate the premiums for abortion services, and they still cannot be covered by premium subsidies. But no separate invoice would be required.
The consumer protection guardrails for 1332 waivers were significantly relaxed in 2018. Few states had expressed interest in utilizing the new rules (the vast majority of 1332 waiver proposals have continued to be for reinsurance programs), but HHS is now proposing that the more stringent 1332 waiver guardrails be restored.
In January, the outgoing Trump administration finalized a program known as “Exchange Direct Enrollment,” designed to allow states to abandon their ACA-created exchanges altogether and rely instead on broker and insurer websites. (Note that this is not the same thing as enhanced direct enrollment, which continues to be an option utilized by dozens of enrollment entities.) HHS has now proposed eliminating the Exchange Direct Enrollment option. The public feedback on the Exchange Direct Enrollment program was almost entirely negative, and no states had expressed an interest in pursuing this idea. (Georgia had already received approval for a 1332 waiver utilizing this concept. That approval is now under review by the Biden administration.)
The final version of the new rules is expected to be published within the next few weeks. We won’t know the status of these proposed rule changes until then, but the proposed changes we’ve discussed here are fairly likely to be finalized, albeit with possible modifications based on public comments that HHS received.
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.
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Four reasons to not wait until January to enroll in an ACA health plan
Reasons to enroll in an ACA health plan by December 15?
Open enrollment for 2022 individual/family health coverage began on November 1. The enrollment window is longer this year, continuing until at least January 15 in nearly every state. (For now, Idaho still plans to end the open enrollment period on December 15.)
The longer open enrollment period does give people some extra wiggle room during the busy holiday season. But for most people, December 15 is still the soft deadline you’re going to want to keep in mind. In most states, that’s the last day you can enroll in coverage that will take effect January 1.
Which states have open enrollment dates past December 15 – but still have January 1 effective dates?
There are some exceptions, however. The following state-run exchanges are giving people extra time to sign up for a plan that takes effect January 1:
But in the rest of the country, you need to enroll by December 15 to have your plan start on January 1. And that’s important for several reasons.
1. Currently uninsured? Delaying your enrollment will mean no coverage in January.
If you’re not already enrolled in ACA-compliant coverage in 2021, the current open enrollment period is your chance to change that for 2022.
But if you wait until the last minute to enroll, you won’t have coverage in place when the new year begins. Instead, you’ll be waiting until February 1 — or March 1 – if you enroll at the last minute in a few states with longer enrollment windows.
2. Currently uninsured or enrolled in a non-marketplace plan? Delayed enrollment might mean missing out on free money.
If you considered marketplace coverage in the past and found it to be unaffordable, you might currently be uninsured or enrolled in a plan that isn’t regulated by the ACA. Or you might have opted to buy ACA-compliant coverage outside the exchange, if you weren’t eligible for premium tax credits (subsidies) the last time you looked.
But thanks to the American Rescue Plan, many people who weren’t eligible for subsidies in previous years will find that they are now. Those subsidies are only available if you’re enrolled in a marketplace/exchange plan, and the current open enrollment period is your chance to make the switch to a marketplace plan.
In addition to being more widely available, premium subsidies are also larger than they were last fall. People who didn’t enroll last year due to the cost may find that coverage now fits in their budget.
Four out of five people shopping for coverage in the 33 states that use the federally-run marketplace (HealthCare.gov) will find that they can get coverage for $10/month or less. And millions of uninsured Americans are eligible for premium-free coverage in the marketplace, but may not realize this.
Waiting until the last minute to enroll in coverage will mean that you leave all that money on the table for January. You can use our subsidy calculator to get an idea of how much your subsidy will be for 2022. Then, make sure you enroll by December 15 so that you’re eligible to claim the subsidy for all 12 months of the year.
3. Letting your plan auto-renew? You might be in for a surprise.
If you already have coverage through the marketplace in 2021 and are planning to just let it auto-renew for 2021, you might wake up on January 1 with coverage and a premium that aren’t what you expected.
Even if you’re 100% happy with the plan you have now, you owe it to yourself to spend at least a little time checking out the available options before December 15. The premium that your insurer charges is likely changing for 2022. And your subsidy amount might also be changing, especially if there are new insurers joining the marketplace in your area.
Your insurer might also be making changes to your benefits, provider network, or covered drug list — or even discontinuing the plan altogether and replacing it with a new one. In short, the plan and price you have on January 1 might be quite different from what you have now.
This is part of the reason HHS opted to extend the open enrollment period – in order to give people a chance for a “do-over” if their auto-renewed plan isn’t what they expected. In nearly every state, you’ll have until at least January 15 to pick a new plan. But that plan selection won’t be retroactive to January 1.
4. Out-of-pocket expenses won’t transfer in February or March.
What if you’re enrolled in a marketplace plan in 2021, let it auto-renew for 2022, and then decide after December 15 that you’d rather have a different plan? Thanks to the extended open enrollment period, you can do that, and your new plan will take effect in February (or potentially March, if you’re in one of the state-run exchanges with the latest enrollment deadlines).
But it’s important to understand that you’ll be starting over with a new plan in February or March. This means the out-of-pocket costs counted against your deductible and out-of-pocket maximum will reset to $0, even if you ended up with out-of-pocket expenses in January.
Out-of-pocket expenses reset to $0 on January 1 for all marketplace plans, so your auto-renewed policy will start over with a new deductible at that point. But if you need medical care in January (and have associated out-of-pocket costs) before your new plan takes effect in February, you’ll potentially have a higher out-of-pocket exposure for the whole year than you would have if you’d picked your new plan by December 15 and had it start January 1.
All of this is a reminder that while most enrollees have until at least mid-January to sign up for 2022 coverage, it’s in your best interest to get your plan selection sorted out by December 15.
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 Four reasons to not wait until January to enroll in an ACA health plan appeared first on healthinsurance.org.
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Think you’re not eligible for ACA subsidies? Think again.
Who should review their eligibility for 2022 health insurance subsidies?
For millions of Americans, the open enrollment period (OEP) to shop for 2022 ACA-compliant coverage will be unlike any of the previous eight OEPs. The reason? These consumers will – for the first time – be able to tap into the Affordable Care Act’s premium tax credits (more commonly referred to as health insurance subsidies).
Thanks to the American Rescue Plan, consumers who in previous years might have found themselves outside the eligible level for subsidies – or who may have found that subsidy amounts were so low as to not be enticing – are now among those eligible for premium tax credits. So if you haven’t shopped for health insurance lately, you might be surprised to see how affordable your health coverage options are this fall (starting November 1), and how many plan options are available in your area.
Millions have already tapped into the subsidies
Most people who currently have coverage through the health insurance exchanges have seen improved affordability this year thanks to the American Rescue Plan (ARP). That includes millions of people who were already enrolled in plans when the ARP was enacted last March, as well as millions of others who signed up during the special enrollment period that continued through mid-August in most states (and is still ongoing in some states).
Use our updated subsidy calculator to estimate how much you can save on your 2021 health insurance premiums.
But there are still millions of others who are either uninsured or have obtained coverage elsewhere. And there are also people who already had coverage in the exchange in 2021 but didn’t take the option to switch to a more robust plan after the ARP was implemented. If you’re in either of these categories, you don’t want to miss the open enrollment period in the fall of 2021.
The Build Back Better Act, which is still under consideration in Congress, would extend the ARP’s subsidies and ensure that health insurance stays affordable in 2023 and beyond. But even without any new legislative action, most of the ARP’s subsidy enhancements will remain in place for 2022.
That means there will continue to be no upper income limit for premium tax credit (subsidy) eligibility, and the percentage of income that people have to pay for the benchmark plan will continue to be lower than it was in prior years. The overall result is that subsidies are larger than they were in the past, and available to more people.
Who should make a point to review their subsidy eligibility?
So who needs to pay close attention this fall, during open enrollment? In reality, anyone who doesn’t have access to Medicare, Medicaid, or an employer-sponsored health plan – because even if you’re already enrolled and happy with the plan you have, auto-renewal is not in your best interest.
But there are several groups of people who really need to shop for coverage this fall. Let’s take a look at what each of these groups can expect, and why you shouldn’t let open enrollment pass you by if you’re in one of these categories:
1. The uninsured – eligible for low-cost or NO-cost coverage
The majority of uninsured Americans cite the cost of coverage as the reason they don’t have health insurance. Yet millions of those individuals are eligible for free or very low-cost health coverage but haven’t yet enrolled. This has been the case in prior years as well, but premium-free or very low-cost health plans are even more widely available as a result of the ARP.
If you’re uninsured because you don’t think health insurance is affordable, know that more than a third of the people who enrolled via HealthCare.gov during the COVID/ARP special enrollment period this year purchased plans for less than $10/month.
Even if you’ve checked in previous years and couldn’t afford the plans that were available, you’ll want to check again this fall, since the subsidy rules have changed since last year.
2. Consumers enrolled in non-ACA-compliant plans
There are millions of Americans who have purchased health coverage that isn’t compliant with the ACA. Most of these plans are either less robust than ACA-compliant plans, or use medical underwriting, or both. They include:
People purchase or keep these plans for a variety of reasons. But chief among them has long been the fact that ACA-compliant coverage was unaffordable – or was assumed to be unaffordable.
There are also people who prefer some of the benefits that some of these plans offer (the fellowship of being part of a health care sharing ministry, for instance, or the abundantly available primary care with a DPC membership). But by and large, the reason people choose coverage that isn’t ACA-compliant, or that isn’t even insurance at all, is because ACA-compliant coverage doesn’t fit in their budgets.
This has long included a few main groups of people: Those who earned too much to qualify for subsidies, those affected by the “family glitch,” and those who qualified for only minimal subsidy assistance and still felt that the coverage available in the exchange wasn’t affordable.
(Another group of people unable to afford coverage are those who earn less than the poverty level in 11 states that have refused to expand Medicaid and thus have a coverage gap. Some people in the coverage gap purchase non-ACA-compliant coverage, but this population is also likely to not have any coverage at all. If you or a loved one are in the coverage gap, we encourage you to read this article.)
The ARP has not fixed the family glitch or the coverage gap, although there are legislative and administrative solutions under consideration for each of these.
But the ARP has addressed the other two issues, and those provisions remain in place for 2022. The income cap for subsidy eligibility has been eliminated, which means that some applicants can qualify for subsidies with income far above 400% of the poverty level. And for those who were already eligible for subsidies, the subsidy amounts are larger than they used to be, making coverage more affordable.
So if you are enrolled in any sort of self-purchased health plan that isn’t compliant with the ACA, you owe it to yourself to check your on-exchange options this fall, during the open enrollment period. Keep in mind that you can do that through the exchange, through an enhanced direct enrollment entity, or with the assistance of a health insurance broker.
3. Buyers enrolled in off-exchange health plans
There are also people who have “off-exchange” ACA-compliant plans that they’ve purchased directly from an insurance company, without using the exchange. (Note that this is not the same thing as enrolling in an on-exchange plans through an enhanced direct enrollment entity, many of which are insurance companies).
There are a variety of reasons people have chosen to enroll in off-exchange health plans over the last several years. And for some of those enrollees, 2022 might be the year to switch to an on-exchange plan.
Since 2018, some people have opted for off-exchange plans if they weren’t eligible for premium subsidies and wanted to enroll in a Silver-level plan. This was a very rational choice, encouraged by state insurance commissioners and marketplaces alike. But if you’ve been buying off-exchange coverage in order to get a Silver plan with a lower price tag, the primary point to keep in mind for 2022 is that you might find that you’re now eligible for premium subsidies.
Just like the people described above, who have enrolled in various non-ACA-compliant plans in an effort to obtain affordable coverage, the elimination of the income limit for subsidy eligibility is a game changer for people who were buying off-exchange coverage to get a lower price on a Silver plan.
Some people have opted for off-exchange coverage because their preferred health insurer wasn’t participating in the exchange in their area. This might have been a deciding factor for an applicant who was only eligible for a very small subsidy — or no subsidy at all — and was willing to pay full price for an off-exchange plan from the insurer of their choice.
But 2022 is the fourth year in a row with increasing insurer participation in the exchanges, and some big-name insurers are joining or rejoining the exchanges in quite a few states. So if you haven’t checked your on-exchange options in a while, this fall is definitely the time to do so. You might be surprised to see how many options you have, and again, how affordable they are.
4. Consumers enrolled in on-exchange plans, but no income details on file and no recent coverage reconsiderations
If you’re already enrolled in an on-exchange plan and you had given the exchange a projection of your income for 2021, you probably saw your subsidy amount increase at some point this year.
But if the exchange didn’t have an income on file for you, they wouldn’t have been able to activate a subsidy on your behalf (on the HealthCare.gov platform, subsidy amounts were automatically updated in September for people who hadn’t updated their accounts by that point, but only if you had provided a projected income to the exchange when you enrolled in coverage for 2021). And even if your subsidy amount did get updated, you might have remained on the plan you had picked last fall, despite the option to pick a different one after the ARP was enacted.
The good news is that you’ll be able to claim your full premium tax credit, for the entirety of 2021, when you file your 2021 tax return (assuming you had on-exchange health coverage throughout the year). And during the open enrollment period for 2022 coverage, you can provide income information to the exchange so that a subsidy is paid on your behalf each month next year.
Reconsidering your plan choice during open enrollment might end up being beneficial as well. If you didn’t qualify for a subsidy in the past, or if you only qualified for a modest subsidy, you might have picked a Bronze plan or even a catastrophic plan, in an effort to keep your monthly premiums affordable.
But with the ARP in place, you might find that you can afford a more robust health plan. And if your income doesn’t exceed 250% of the poverty level (and especially if it doesn’t exceed 200% of the poverty level), pay close attention to the available Silver plans. The larger subsidies may make it possible for you to afford a Silver plan with built-in cost-sharing reductions that significantly reduce out-of-pocket costs.
One other point to keep in mind: If you are receiving a premium subsidy this year, be aware that it might change next year due to a new insurer entering the market in your area and offering lower-priced plans. Here’s more about how this works, and what to consider as you’re shopping for coverage this fall.
The takeaway point here? Even if you’ve been happy with your plan, you should check your options during open enrollment. This is not the year to let your plan auto-renew. Be sure you’ve provided the exchange with an updated income projection for 2022, and actively compare the plans that are available to you. It’s possible that a plan with better coverage or a broader provider network might be affordable to you for 2022, even if it was financially out of reach when you checked last fall.
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 Think you’re not eligible for ACA subsidies? Think again. appeared first on healthinsurance.org.
Congress boosted ACA subsidies. An enrollment surge followed.
The American Rescue Plan, signed into law by President Biden on March 11 of this year, included major boosts to the affordability of health plans sold in the ACA marketplace for people of all incomes.
Effective through 2022 and likely to be made permanent by pending legislation, the ARP improvements to affordability were as follows:
Our 2022 Open Enrollment Guide: Everything you need to know to enroll in an affordable individual-market health plan.
Preceding and then coinciding with these major subsidy boosts, the Biden administration had opened an emergency Special Enrollment Period (SEP) running from February 15 through August 15 in the 36 states that use the federal ACA exchange, HealthCare.gov.
The SEP, implemented to help Americans get covered during the pandemic, functioned like a second open enrollment period: anyone who lacked access to affordable coverage from other sources (e.g., employers) could enroll in a marketplace plan. The 15 state-based exchanges also opened emergency SEPs, with somewhat different durations and conditions, summarized here.
ARP prompted an enrollment surge during the 2021 SEP
The enhanced subsidies were posted on HealthCare.gov on April 1, and in the state-run exchanges within a few weeks of that date. Existing enrollees were encouraged to update their information and get the new subsidies credited, and were allowed to switch plans if they chose.
Americans responded with a major surge in new enrollment and enrollment upgrades. From February 15 through August 15:
Savings were also dramatic for existing marketplace enrollees:
My premium went down how much?
To get a sense of the extent to which the ARP reduced enrollee costs (or encouraged people who might previously have considered coverage too expensive to enroll), consider these examples:
Now, this couple can choose to pay $393 per month for the Gold plan (which includes free doctor visits and generic drug prescriptions, neither subject to the deductible), or consider two free Bronze plans with deductibles over $8,000, a $2/month Bronze plan with a $6,100 deductible, and other options. A BlueCross Silver plan available for $420 per month might also be in the mix, if, say, the provider network is preferable.
Which states saw the biggest gains in new enrollees?
The new enrollment surge – and the savings – was particularly strong in twelve states that had not enacted the ACA Medicaid expansion as of June 2021. Due to their failure to expand Medicaid, these states have a “coverage gap” for people who earn too little to qualify for marketplace coverage (less than 100% FPL, or $12,760 for an individual in 2021) but mostly also don’t qualify for Medicaid because of their states’ restrictive Medicaid eligibility. (That excludes Wisconsin, which has not enacted the ACA expansion but grants Medicaid eligibility to adults with income up to 100% FPL. Oklahoma, which expanded Medicaid beginning in July 2021, and Missouri, which will begin covering new Medicaid expansion enrollees in October, are included.)
These twelve states – Alabama, Florida, Georgia, Kansas, Missouri, Mississippi, North Carolina, Oklahoma, South Carolina, South Dakota, Tennessee, Texas and Wyoming – accounted for 1.55 million new enrollees during the SEP, or 55% of all new enrollees nationally.
In the non-expansion states, eligibility for marketplace subsidies begins at 100% FPL, as opposed to 138% FPL in Medicaid expansion states, where adults below that threshold qualify for Medicaid. Accordingly, in these states, about half of enrollees qualified for free high-CSR coverage, reporting incomes between 100% and 150% FPL. In these states, enrollment as of August 2021 (6.0 million) was 44% above enrollment in August 2019, the last pre-pandemic year (4.2 million).
More than 2 million people in non-expansion states are estimated to be stuck in the coverage gap – ineligible both for Medicaid and for ACA premium subsidies. For people in these states, reporting an income just below or just above 100% FPL ($12,760 for an individual, $26,200 for a family of four) is the difference between receiving no help at all and having access to free Silver coverage with high CSR and low out-of-pocket costs.
It’s important to keep in mind that the application for marketplace coverage requires an income estimate – and many people, unaware of the minimum income requirement, underestimate their potential income. For tips on how to make sure you leave no stone unturned in seeking help paying for coverage, see this post.
What do these numbers mean for 2022 open enrollment?
As open enrollment for 2022 approaches (it begins on November 1), the subsidies enhanced by the ARP remain in place for 2022. As Congress hashes out new investments for coming years in a pending budget bill, the pressure is intense to keep this good thing going in future years.
As of now, with the sad exception of those stuck in the coverage gap in states that still refuse to enact the ACA Medicaid expansion, any citizen or legally present noncitizen who lacks access to other forms of affordable coverage should be able to find it in the marketplace. If you need coverage, make sure to check out your options on HealthCare.gov or your state exchange.
The word that ACA marketplace plans are more affordable than ever has not yet reached many of the people who need coverage and qualify for premium subsidies. The Kaiser Family Foundation estimated in May that nearly 11 million uninsured people were subsidy-eligible. ACA enrollment assisters consistently report that many people who are eligible for coverage have no idea what’s on offer.
The Biden administration is trying to change that: after years of radical cuts in federal funds for enrollment assistance, the administration this year has allocated a record $80 million to fund nonprofit enrollment “navigator” groups charged with outreach as well as enrollment assistance. The Urban Institute forecast that if the ARP subsidies are made permanent – solidifying the perception that truly affordable coverage is here to stay — enrollment would increase by more than 5 million in 2022.
The emergency SEP provided a jump start, boosting coverage as of August more than 1.5 million above the August 2020 level. In a fraught and complex legislative session, Congress will most likely – though not certainly – do its part and extend the subsidies beyond 2022. There is certainly room for enrollment to run higher in the open enrollment season that begins on November 1.
Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid. His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic, and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D. in English literature from the University of Rochester.
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Subsidy availability drives consumers to shop for health insurance
A major premise of the Affordable Care Act (ACA) was that Americans who need to buy their own health coverage in the individual market should be able to obtain coverage – regardless of their medical history – and that the monthly premiums should be affordable.
The rules to facilitate those goals have been in place for several years now. And although they have worked quite well for some Americans, there have been others for whom ACA-compliant health coverage was still unaffordable.
But the American Rescue Plan, enacted earlier this year, has boosted the ACA’s subsidies, making truly affordable coverage much more available than it used to be.
The numbers speak for themselves: Exchange enrollment has likely reached a record high of nearly 13 million people in 2021, after more than 2.5 million people enrolled during the COVID/American Rescue Plan enrollment window, which ended this month in most states.
How much are consumers saving on health insurance premiums?
And the amount that people are paying for their coverage and care is quite a bit lower than it was before the APR’s subsidy enhancements. We can see this across the states that use the federally run exchange (HealthCare.gov), as well as the states that run their own exchanges:
These examples highlight the improved affordability that the ARP has brought to the health insurance marketplaces. People who were already eligible for subsidies are now eligible for larger subsidies. And many of the people who were previously ineligible for subsidies — but potentially facing very unaffordable health insurance premiums — are benefiting from the ARP’s elimination of the income cap for subsidy eligibility.
How long will the ARP’s subsidy boost last?
Although the ARP’s subsidies for people receiving unemployment compensation in 2021 are only available until the end of this year, the rest of the ARP’s premium subsidy enhancements will continue to be available throughout 2022 — and perhaps longer, if Congress extends them.
Use our updated subsidy calculator to estimate how much you can save on your 2021 health insurance premiums.
This means that the affordability gains we’ve seen this year will be available during the upcoming open enrollment period, when people are comparing their plan options for 2022.
Robust ACA-compliant coverage will continue to be a more realistic option for more people, reducing the need for alternative coverage options such as short-term plans, fixed indemnity plans, and health care sharing ministry plans.
Even catastrophic plans – which are ACA-compliant but not compatible with premium subsidies – are likely to see reduced enrollment over the next year, since more people are eligible for enhanced subsidies that make metal-level plans more affordable.
Can everyone find affordable health insurance now?
Unfortunately, not yet. There are still affordability challenges facing some Americans who need to obtain their own health coverage. That includes more than two million people caught in the “coverage gap” in 11 states that have refused to expand eligibility for Medicaid, as well as about 5 million people affected by the ACA’s “family glitch.”
There are strategies for avoiding the coverage gap if you’re in a state that hasn’t expanded Medicaid, and Congressional lawmakers are also considering the possibility of a federally-run health program to cover people in the coverage gap.
Families affected by the family glitch have access to an employer-sponsored plan that’s affordable for the employee but not for the whole family – and yet the family is also ineligible for subsidies in the marketplace/exchange. (It’s possible that the Biden administration could tackle this issue administratively in future rulemaking.)
Have ARP’s subsidy boosts been successful?
With the exception of those two obstacles, the ARP has succeeded in making affordable health coverage a more realistic option for most Americans who need to obtain their own health coverage. We can see success in the record-high exchange enrollment, the increased percentage of enrollees who are subsidy-eligible, and the reduction in after-subsidy premiums that people are paying.
If you’re currently uninsured or covered by a non-ACA-compliant plan (including a grandfathered or grandmothered plan), it’s in your best interest to take a moment to see what your options are in the ACA-compliant market. Open enrollment for 2022 coverage starts in just two months, but you may also find that you can still enroll in a plan for the rest of 2021 if you live in a state where a COVID/American Rescue Plan enrollment window is ongoing, or if you’ve experienced a qualifying event recently (examples include loss of employer-sponsored insurance, marriage, or the birth or adoption of a child).
Even if you shopped just last winter, during open enrollment for 2021 plans, you might be surprised at the difference between the premiums you would have paid then and now. The ARP wasn’t yet in effect during the last open enrollment period, so if you weren’t eligible for a subsidy last time you looked, or if the plans still seemed too expensive even with a subsidy, you’ll want to check again this fall.
The subsidies for 2022 will continue to be larger and more widely available than they’ve been in the past, and you owe it to yourself to see what’s available in your area.
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.
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Lost your job? Here’s how to keep your health insurance or find new coverage now.
Most Americans under the age of 65 get their health insurance from an employer. This makes life fairly simple as long as you have a job that provides solid health benefits: All you need to do is enroll when you’re eligible, and if your employer offers a few options from which to choose, pick the one that best fits your needs each year during your employer’s annual enrollment period.
But the downside to having health insurance linked to employment is that losing your job will also mean losing your health insurance, adding stress to an already stressful situation.
The good news is that you’ve got options — probably several, depending on the circumstances. Let’s take a look at what you need to know about health insurance if you’ve lost your job and are facing the loss of your employer-sponsored health coverage.
Can I enroll in self-purchased insurance as soon as I’ve lost my job?
If you’re losing your job-based health insurance, you do not have to wait for the fall open enrollment period to sign up for a new ACA-compliant plan.
Although the COVID-related special enrollment window for individual/family health plans has already ended in most states, you’ll qualify for your own special enrollment period due to the loss of your employer-sponsored health plan.
This will allow you to enroll in a plan through the marketplace/exchange and take advantage of the subsidies that are available (and bigger than ever, thanks to the American Rescue Plan), without having to wait until 2022 to get coverage.
If you enroll prior to your coverage loss, your new plan will take effect the first of the month after your old plan ends, which means you’ll have seamless coverage if your old plan is ending on the last day of the month.
Your special enrollment period also continues for 60 days after your coverage loss, although you’d have a gap in coverage if you wait and enroll after your old plan ends, since your new plan wouldn’t take effect retroactively.
If you’re in that situation, you might find that a short-term health plan is a good option for bridging the gap until your new plan takes effect. Short-term plans won’t cover pre-existing conditions and are not regulated by the Affordable Care Act (ACA). But they can provide fairly good coverage for unexpected medical needs during a temporary window when you’d otherwise be uninsured.
Be sure to check your options again during open enrollment
If you sign up for coverage now in your special enrollment period, keep in mind that you’ll still need to re-evaluate your coverage during the upcoming open enrollment period, which begins November 1. Even though you’re enrolling fairly late in 2021, your new plan will reset on January 1, with new pricing and possibly some coverage changes. There also might be new plans available in your area for 2022.
So your special enrollment period (tied to your coverage loss) will be your opportunity to find the best plan to fit your needs for the rest of this year. And if you’re still going to need self-purchased coverage in 2022, the upcoming open enrollment period will give you a chance to make sure you optimize your coverage for next year as well.
COBRA (or state continuation) versus self-purchased coverage
Depending on the size of your employer, COBRA might be offered to you. And even if your employer is too small for COBRA, you might have access to state continuation (“mini-COBRA”), depending on where you live. Either of these options will allow you to temporarily continue the coverage you already have, instead of switching to a new individual-market plan right away.
If COBRA or state continuation is available, your employer will notify you and give you information about what you’ll need to do to activate the coverage continuation and how long you can keep it.
Normally, you have to pay the full cost of COBRA or state continuation coverage, including the portion that your employer previously paid on your behalf — which was likely the bulk of the premiums. But until the end of September 2021 (so for just one more month), as part of the American Rescue Plan (ARP), the federal government will pay the full cost of COBRA or state continuation coverage for people who involuntarily lost their jobs.
For much of this year, the soon-to-end COBRA subsidy has changed the calculus that normally goes into the decision of whether to continue an employer-sponsored plan or switch to a self-purchased individual/family plan. But after the end of September, the normal decision-making process will again apply. And you’ll have a special enrollment period when the COBRA subsidy ends, which will allow you to transition to an individual/family plan at that point if you want to.
COBRA coverage vs individual-market health insurance
Here’s what to keep in mind when you’re deciding between COBRA and an individual-market health plan – either initially, or after the COBRA subsidy ends on September 30:
Free health insurance if you collected unemployment in 2021
If you’re approved for even one week of unemployment compensation in 2021, you qualify for a premium subsidy that will fully cover the cost of the two lowest-cost Silver plans in the marketplace/exchange in your area, through the end of the year.
The subsidy will also likely cover the full cost of many of the Bronze plans, and possibly some of the Gold plans, depending on the pricing of plans where you live. This is a special subsidy rule created by the ARP, for 2021 only.
In addition to the subsidy that will allow you to get a free Silver plan, it will also ensure that any of the available Silver plans have full cost-sharing reductions.
What if my income is too low for subsidies?
In order to qualify for premium subsidies for a plan purchased in the marketplace, you must not be eligible for Medicaid, Medicare, or an employer-sponsored plan, and your income has to be at least 100% of the federal poverty level. (As noted above, for 2021 only, you’re eligible for subsidies if you receive unemployment compensation, regardless of your actual total income for the year, as long as you’re not eligible for Medicaid, Medicare, or an employer’s plan.)
In most states, the ACA’s expansion of Medicaid eligibility provides coverage to adults with household income up to 138% of the poverty level, with eligibility determined based on current monthly income. So if your income has suddenly dropped to $0, you’ll likely be eligible for Medicaid and could transition to Medicaid when your job-based coverage ends.
Unfortunately, there are still 11 states where most adults face a coverage gap if their household income is below the federal poverty level. They aren’t eligible for premium subsidies in the marketplace (unless they’ve received unemployment compensation in 2021 and can thus qualify for 2021 subsidies).
This is an unfortunate situation that those 11 states have created for their low-income residents. But there are strategies for avoiding the coverage gap if you’re in one of those states.
And keep in mind that subsidy eligibility in the marketplace is based on your household income for the whole year, even if your current monthly income is below the poverty level. So if you earned enough earlier in the year to be subsidy-eligible for 2021, you can enroll in a plan with subsidies based on that income, despite the fact that you might not earn anything else for the rest of the year.
When open enrollment begins in November, you’ll need to project your 2022 income as accurately as possible, if you’re still needing to purchase your own coverage for 2022. But for the rest of 2021, you can use the income you already earned this year to qualify for subsidies.
What if I’ll soon be eligible for Medicare?
There has been an increase recently in the number of people retiring in their late 50s or early 60s, before they’re eligible for Medicare. The ACA made this a more realistic option starting in 2014, thanks to premium subsidies and the elimination of medical underwriting.
And the ARP has boosted subsidies and made them more widely available for 2021 and 2022, making affordable coverage more accessible for early retirees. That’s especially true for those whose pre-retirement income might have made them ineligible for subsidies in the year they retired, due to the “subsidy cliff” (which has been eliminated by the ARP through the end of 2022).
So if you’re losing your job or choosing to leave it and you still have a few months or a few years before you’ll be 65 and eligible for Medicare, rest assured that you won’t have to go uninsured.
You’ll be able to sign up for a marketplace plan during your special enrollment period triggered by the loss of your employer-sponsored plan. And even if you earned a fairly robust income in the earlier part of the year, you might still qualify for premium subsidies to offset some of the cost of your new plan for the rest of 2021.
You’ll then be able to update your projected income for 2022 during the upcoming open enrollment period; your subsidies will adjust in January to reflect your 2022 income.
And marketplace plans are always purchased on a month-to-month basis, so you’ll be able to cancel your coverage when you eventually transition to Medicare, regardless of when that happens.
Don’t worry, get covered
The short story on all of this? Coverage is available, and obtaining your own health plan isn’t as complicated as it might seem at first glance, even if you’ve had employer-sponsored coverage all your life.
You can sign up outside of open enrollment if you’re losing your job-based insurance, and there’s a good chance you’ll qualify for financial assistance that will make your new plan affordable.
You can learn more about the marketplace in your state and the available plan options by selecting your state on this map. And there are zero-cost enrollment assisters – Navigators and brokers – available throughout the country to help you make sense of it all.
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.
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The COVID SEP ended in most states. The ARP is still making premiums more affordable.
Although August 15 marked the end of a one-time COVID-related special enrollment period (SEP) for marketplace health insurance in most states, the enhanced subsidies that enticed millions of consumers are still available for many individual-market buyers (as noted below, the SEP is ongoing in some states).
The American Rescue Plan’s enhancements to the Affordable Care Act’s health insurance subsidies will continue long after the end of the COVID SEP. That means that when you do have an opportunity to buy coverage again – either through open enrollment or due to a personal qualifying life event – you’ll likely find individual health insurance much less expensive than you might have expected.
The ARP’s affordability provisions are still helping with premiums
As we’ve noted over the past few months, the American Rescue Plan included numerous provisions that make ACA-compliant plans more affordable than ever. The additional health insurance subsidy enhancements delivered by the ARP include:
All of those benefits continue to be available. The additional subsidies based on unemployment compensation continue through the end of 2021, while the other subsidy enhancements will be available through the end of 2022 (and possibly longer, if Congress extends them).
How popular are the ARP’s subsidy enhancements?
HHS reported last week that more than 2.5 million people had already enrolled in coverage during the COVID-related special enrollment period, and that another 2.6 million existing marketplace enrollees had activated their ARP subsidies.
Among all of the new enrollees, average after-subsidy premiums were just $85/month, as opposed to $117/month before the ARP’s subsidies became available. And across all of the new and renewing enrollees, about 35% had obtained coverage with after-subsidy premiums of less than $10/month.
That illustrates how substantial premium subsidies have become under the ARP. And again, nothing has changed about those subsidies: the special enrollment window has ended in most states, but the subsidies are still available if you’re eligible to enroll for the remainder of 2021 — and again during open enrollment for 2022, which starts November 1.
So if you’re in a state where enrollment is still open, or if you’re eligible for an individual special enrollment period in any state, it’s certainly in your best interest to see what plan options are available to you.
Enrolling as soon as you’re eligible will mean that you’re able to start taking advantage of the ARP’s subsidies right away, rather than having to wait for open enrollment and coverage that starts in 2022.
States where enrollment continues
Although the COVID SEP ended on August 15 in the states that use HealthCare.gov – and some of the states that run their own exchanges – enrollment is still actually ongoing in several states:
Enrollment if you have a qualifying life event
Not in one of those states? Special enrollment periods are available to individuals who experience a wide range of “life changes.” The most common trigger for a personal SEP is a loss of other coverage — usually job-based coverage.
(Note that there’s usually only a 60-day window to enroll in a new plan after losing other coverage. But HealthCare.gov is making an exception for people who lost their coverage as long ago as January 2020, if they missed their enrollment deadline because they were “impacted by the COVID-19 emergency.” People who need to utilize this flexibility have to call the marketplace directly to qualify for a special enrollment period on a case-by-case basis.)
In addition to a loss of coverage, there are also other situations in which you’ll qualify for a SEP. They include events such as the birth or adoption of a child, marriage (as long as at least one spouse already had minimum essential coverage), or even your grandmothered or grandfathered plan coming up for renewal.
More opportunities to enroll in ACA-compliant coverage
In addition to the states with ongoing COVID-related enrollment periods and the individual SEPs triggered by qualifying life events, there are other circumstances under which you might still be eligible to enroll in affordable health coverage:
Mark your calendar for 2022 open enrollment
If you don’t have an enrollment period now, be sure to mark your calendar for the start of open enrollment on November 1. That’s when you’ll be able to sign up for health coverage that will take effect in January, with coverage for essential health benefits and pre-existing conditions. During open enrollment, your medical history won’t matter, and neither will your coverage history.
And if you’re already enrolled in an ACA-compliant plan – or soon will be – you’ll still want to pay attention to open enrollment this fall. There are new insurers joining the marketplaces in many areas, which might have an unexpected effect on your premium subsidy. And even if you’re happy with the plan you have now, you might find that a different plan works better for the coming year.
Fortunately, the ARP’s subsidy enhancements will continue to be available for 2022. So if you’re eligible for subsidies – and most people are – your coverage for next year is likely to be quite affordable.
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 The COVID SEP ended in most states. The ARP is still making premiums more affordable. appeared first on healthinsurance.org.
How new carriers in your marketplace could affect your coverage options
Recent news about individual-market health insurance has been largely centered around the American Rescue Plan and how it’s made coverage in 2021 much more affordable than it used to be. Now, as we approach ACA’s annual open enrollment period, it’s a good time to look ahead to what we can expect to happen with 2022 coverage.
Fortunately, the ARP’s enhanced subsidies will still be in effect in 2022 – and possibly longer, if Congress can agree on an extension. That means subsidies will continue to be larger than they used to be, and more widely available, including to households earning more than 400% of the poverty level.
For 2022 individual/family coverage, we’re seeing some wide variation in proposed and finalized rate changes across the country. Average rates will decrease in some areas and increase in others, with modest single-digit rate changes in most places.
(Since the ARP has eliminated the income cap for subsidy eligibility for 2021 and 2022, few enrollees will see these rate changes reflected in their actual premiums, since most enrollees get premium subsidies. But rate changes do affect the size of the subsidy amount, and that can result in changes for after-subsidy premiums, as explained below.)
Increased insurer participation in marketplaces continues
But we’re also seeing widespread continuation of the increasing insurer participation trend that’s been ongoing since 2019. In 2017 and 2018, insurers fled the ACA’s exchanges – or even the entire individual/family market. But that started to turn around in 2019, and insurer participation increased again in 2020 and 2021.
For 2022, that trend is continuing. Some big-name insurers that previously scaled back their marketplace participation are rejoining various marketplaces, and some smaller regional insurers are joining marketplaces or expanding their existing footprints.
Where are new carriers entering ACA’s marketplace for 2022?
Here’s a summary of some of the major individual/family insurers that are entering new markets for 2022:
More carriers = more plan options …
That’s in addition to numerous coverage area expansions by existing marketplace insurers in many states. Based on the rate filings that we’ve analyzed thus far, we anticipate that many – if not most – marketplace enrollees will have more plan options available for 2022 than they had this year.
One of the goals of the ACA was to increase competition in the individual health insurance market. The exchanges are set up to facilitate that, with enrollees able to compare options from all of the participating insurers and select the plan that best fits their needs.
From that perspective, increasing insurer participation and competition in the exchange is good. And it does give people more plans from which to choose, which can also be a good thing. But too many choices can overwhelm applicants and result in poor decision making.
… and a new carrier could also affect premium subsidies
In addition to delivering more plan options, carriers expanding into an area might also affect premium subsidies in that area. How much effect will depend on how the new plans are priced in comparison with the existing plans – keeping in mind that rates change each year on January 1 regardless of whether any new insurers are entering the market.
Premium subsidy amounts are based on the cost of the benchmark plan in each area. But since that just refers to the second-lowest-cost Silver plan, it’s not necessarily the same plan from one year to the next. If a new insurer enters the market with low-priced plans, the insurer may undercut the current benchmark and take over the second-lowest-cost spot. If the premium is lower than the benchmark plan’s price would otherwise have been, the result is smaller premium subsidies for everyone in that area.
For people in that area who prefer to keep their existing plan (as opposed to switching to the new lower-cost options), this can result in an increase in after-subsidy premiums, since the subsidies are smaller than they would otherwise have been. We can see an example of this in the Phoenix area in 2019 and 2020, when new insurers entered the market with lower-priced plans that reduced the size of premium subsidies in the area.
To clarify, anything that reduces the cost of the benchmark premium will result in smaller subsidies. This can be a new lower-cost insurer entering the market, or existing insurers reducing their rates. An example of this can be seen in how after-subsidy premiums increased for many of Colorado’s exchange enrollees in 2020, when the state’s new reinsurance program reduced average pre-subsidy premiums by about 20%. The reduction helped unsubsidized enrollees (mostly those with incomes over the limit for subsidy eligibility, which has been removed at least through 2022) but resulted in higher net premiums for many enrollees who qualified for subsidies.
Although the vast majority of exchange enrollees do qualify for premium subsidies (especially now that the American Rescue Plan has eliminated the “subsidy cliff” for 2021 and 2022) some enrollees do not. For these enrollees, the introduction of a new insurer simply broadens their plan options, and does not affect their premiums unless they choose to switch to the new plan.
And of course, if the new insurer has plans that are priced higher than the existing benchmark plan, the carrier’s entry will not affect net premiums paid by subsidized enrollees.
Plan to compare your coverage options during open enrollment
It will be several weeks before all the details are clear in terms of rate changes and plan availability for 2022 coverage. But it appears that the trend of increasing competition in the exchanges will continue.
And although the American Rescue Plan’s enhanced subsidy structure will still be in place in 2022 – making subsidies larger and more widely available than they would otherwise have been – it’s still possible for a new insurer to disrupt the market and end up adjusting the size of premium subsidies in a given area.
Open enrollment for 2022 coverage will begin November 1. Actively comparing your options during open enrollment is always the best approach, and that’s especially true if a new insurer will be offering plans in your area. Letting your current plan auto-renew without comparison shopping is never in your best interest.
If a new insurer is joining the marketplace, you may find that its plans are a perfect fit for your needs. Or you might find that your best option is to switch to a different plan because your after-subsidy premiums are increasing due to the new insurer undercutting the price of the current benchmark plan. Switching plans might be a non-starter due to your provider network or drug formulary needs, but you won’t know for sure until you consider the various options that are available to you.
Ask a professional how a new carrier could impact your coverage
We have an overview of factors to keep in mind when you’re choosing a health plan, but it’s also worthwhile to seek out professional advice. Enrollment assistance is available from brokers, enrollment counselors, and Navigators.
Brokers are licensed and regulated by state insurance departments, and must also have certification from the exchange in order to help people enroll in health plans offered through the exchange. Training and testing are necessary in order to obtain the license and certification, and brokers must also complete ongoing continuing education in order to maintain their credentials.
Broker training encompasses a wide range of topics, including ethics, fraud prevention, evolving insurance laws and regulations, and health plan details. The training and regulatory oversight make brokers a reliable source of information and assistance with initial plan selections and enrollments as well as future issues that might arise as the health plan is utilized.
Navigators should be much more widely available this fall, as the Biden administration has allocated $80 million for this year’s Navigator grants in the states that use HealthCare.gov. (The previous high was $63 million in 2016; the Trump administration subsequently reduced it to $36 million in 2017 and to $10 million each year from 2018 through 2020.) The Biden administration has also proposed a return to expanded duties for Navigators, which would provide consumers with increased access to post-enrollment assistance with their coverage.
In short, enrollment assistance should be widely available this fall, and it’s in your best interest to use it. A recent report from Young Invincibles highlights the myriad ways that enrollment assisters help consumers – it’s more than just picking a plan.
Regardless of where you seek assistance, it won’t cost you anything – and a broker, Navigator, or enrollment counselor will be able to help you determine the impact of any new insurers that will be offering plans in your area for 2022, and help you make sense of the options available to you.
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.
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Six strategies for avoiding the Affordable Care Act’s coverage gap
In eleven of the twelve states that have so far refused to enact the Affordable Care Act’s expansion of Medicaid eligibility (which the Supreme Court made optional for states in 2012), there’s good news and bad news for people who are seeking health insurance for 2022 and don’t earn a lot of income.
The good news is that COVID-19 relief legislation signed by President Biden in March of this year, the American Rescue Plan Act, vastly improved subsidies in the ACA private plan marketplace. Comprehensive coverage – a Silver plan with strong cost-sharing reductions – is now free to many low-income Americans, and heavily subsidized for people who earn a bit more.
The bad news is that in states that have refused to enact the Medicaid expansion, the government still offers no help to people who report household incomes below the poverty line.
ACA’s coverage gap
The ACA’s creators intended for people in this income category to get Medicaid, but governors and legislators in the twelve “nonexpansion” states said no – even though the federal government foots 90% of the cost. More than 2 million low-income adults in these states are in the ACA’s coverage gap – eligible neither for Medicaid nor for help paying for coverage in the ACA private plan marketplace.
The remaining non-expansion states (excluding Wisconsin, which has no coverage gap,* and Missouri, where expansion is imminent) are as follows:
The minimum income to qualify for subsidized marketplace coverage in “nonexpansion” states is 100% of the federal poverty level (FPL). For enrollment in 2022, the cutoffs are as follows. (They are slightly lower for those still seeking coverage for the remainder of 2021.)
family/household
(minimum to qualify for coverage)
A Silver plan with strong cost-sharing reduction is free to enrollees with incomes between 100% FPL and 150% FPL. (In 2022, that’s $19,230 for an individual, $39,750 for a family of four.) At 150-200% FPL, Silver coverage costs no more than 2% of income.
At incomes above 200% FPL, the percentage of income required for a benchmark Silver plan rises with income to a maximum of 8.5% of income. But again, in non-expansion states, subsidies are not available to people in households with incomes below 100% FPL.
Stumbling blind into the coverage gap
The application for coverage on HealthCare.gov – the federal marketplace for health coverage used by all of the non-expansion states (and 24 other states) – does not highlight the minimum income required for coverage. As a result, many low-income applicants who might expect to get federal aid find themselves confronted with a choice of plans quoted at full, unsubsidized cost – an average of $452 per month per adult for benchmark Silver coverage, unaffordable for almost all low-income enrollees.
Very few low-income enrollees know about the minimum income requirement, or know that their state legislatures and governors have denied them the Medicaid coverage that the ACA’s creators intended for them.
Many who work uncertain hours, or are self-employed, or do seasonal work, may not recognize how many variables go into their estimate of annual household income, which determines the size of subsidy – or whether a subsidy is available at all.
For applicants with incomes near the federal poverty line, knowing the stakes – that good coverage is free just above the 100% FPL threshold, and unaffordable just below that threshold – can make the difference between coverage and no coverage. For anyone not on a fixed salary, a good-faith estimate of next year’s income allows for some wiggle room. Many applicants may miss including allowable income sources, or fail to take fluctuations in their income into account, or otherwise miss the opportunity to claim a qualifying income.
A budget resolution introduced last week by Sen. Bernie Sanders proposes to create a new federal program that would offer insurance to people in this “coverage gap.” But with Democrats holding narrow majorities in both houses of Congress, their ability to create such a program is at best uncertain. Even if they do, it likely won’t go into effect in 2022.
Open enrollment for 2022 in non-expansion states begins on November 1 and HHS has proposed an end date of January 15. For those still seeking coverage in 2021, an emergency special enrollment period open to all who lack coverage ends soon – on August 15. After that date, you need a qualifying “life change” to get coverage for the remainder of 2021.
Six tactics for avoiding the coverage gap
Here is a checklist of strategies that may help you achieve eligibility for subsidized ACA coverage.
1. Know the eligibility cutoff. As noted above, to qualify for subsidized coverage, an applicant must estimate an annual income for the coming year that’s above 100% of the Federal Poverty Level ($12,880 for an individual, $17,420 for a couple, etc. in 2022. See the list above.) This point can’t be emphasized enough, according to Shelli Quenga, Director of Programs at the Palmetto Project, a nonprofit health insurance brokerage in South Carolina. “You need to know what amount you’re shooting for,” Quenga says. “You need to know where that line is. HealthCare.gov does not tell you.”
2. Use gross income, not net. Many applicants don’t recognize these terms, which denote income before and after taxes. Gross income, which the application requires, is basically the largest number on the pay stub or tax form.
3. Consider earning more income if necessary. When clients’ estimates fall short, Quenga will ask them what they can do to hit the target. “I’ll say, ‘Can you think of something you can do that’s going to earn you another $150 a month? Bake cakes? Clean houses? Mow grass? Do some babysitting? Provide some care to a nearby elderly person?’” Extra income of this sort can be entered on the application as self-employment, with wage income entered elsewhere.
4. Recognize uncertainty. The marketplace application for coverage provides a box to check “if you think your income will be difficult to predict.” That’s the case for many people – especially at low wages. If it’s hard to forecast how many hours you’ll work per week, how much you’ll make per hour (tips or overtime may make this variable), or how much work you’ll get if you’re self-employed, keep the eligibility threshold in mind as you estimate these factors.
5. Count everyone’s income. Household income includes income earned by everyone included in your tax return, including those who are not seeking coverage. Jennifer Chumbley Hogue, CEO of KG Health Insurance in Murphy Texas, cites the case of a woman in her early 60s whose husband is on Medicare and Social Security. “If your spouse is getting Social Security income, don’t forget to include it,” she says. That also holds for pensions, retirement accounts, and alimony (if awarded before 2019).
6. Consider how to count. The application allows you to estimate income on an hourly, weekly, twice-monthly, monthly or annual basis – and, if your income changes during the year, it invites you to estimate a different income for next year than for the current year. This flexibility allows you to take account of factors described below.
You can view the application on the HealthCare.gov site here. The income questions are on page 3. Note that the form recognizes the uncertainty involved in forecasting future income.
Considerations for individuals earning an hourly wage
If your income estimate is based on an hourly wage, consider the following questions:
Many who report income on an hourly wage basis work uneven and uncertain schedules. If a single person is unsure how many hours per week they’re likely to work, “I often tell them to put down 30 hours,” says Hogue – an amount that generally will qualify a solo applicant for coverage at an hourly wage of $8.50 or higher.
Strategies for the self-employed
Many of the low-income clients served by the Palmetto Project are self-employed, Quenga says. “Charleston is a huge destination wedding site. We have a lot of wedding planners, DJs, photographers, videographers.” Estimating next-year income is especially difficult if you’re self-employed, Quenga notes.
And for the self-employed, “Your projected income is your best guess of what you hope to earn.” She notes that the self-employed are generally oriented toward minimizing their income for tax purposes. For the health insurance application, they have to reverse that mindset.
Considerations when estimating your income for 2022
When you apply for coverage for 2022 (or the remainder of 2021), you may have your 2020 tax return to refer to, as well as well as pay stubs for at least 10 months’ income in 2021. If the totals for 2020 or 2021 are below the eligibility cutoff, that’s not necessarily going to be true in the year following. When estimating income in this case, consider these questions:
Were your hours cut because of the pandemic? Regardless, can you realistically expect to work more hours in 2022 (or the remainder of 2021)? These questions apply to everyone in your household – that is, all who file taxes together and earn any income. If so, you can estimate a higher income for the coming year in good faith.
Should you check off allowable tax deductions? The health insurance application asks about tax deductions that, if taken, reduce your gross income. The application points out that reporting these deductions “could make the cost of health coverage a little lower.” That’s true – if your income is above 150% FPL (Coverage is free up to that threshold.)
But if your income hovers near 100% FPL, these deductions could put your income below that threshold and disqualify you from subsidized coverage. The deductions listed on the application are those taken for interest paid on student loans, tuition and fees, retirement plan contributions, and alimony paid. If your income is near the cutoff, “do not check off a deduction that will put you under 100% FPL,” says Hogue.
If you were unemployed in any part of 2021 The American Rescue Plan provides free marketplace coverage in 2021 for any applicant who received any unemployment insurance income at any point in the year. After the emergency special enrollment period (SEP) ends on August 15, you will need to apply for a personal SEP to access this benefit – and do so within 60 days of having lost employer-sponsored coverage or experienced another qualifying life event. This particular benefit is not available in 2022.
What if your income estimate turns out to be higher than what you actually earn?
Low-income applicants may worry that they will owe large sums of money if their income estimate proves inaccurate. While those who underestimate their income do have to pay back a portion of their subsidy at tax time, that is not the case for those who overestimate income (in fact, if over-estimators pay any premium at all, they will get a partial refund).
If income for the year in question ultimately proves to fall below the 100% FPL threshold, there is no clawback of subsidies granted, unless the applicant’s income estimate is made with “intentional or reckless disregard for the facts.”
Your income estimate has to be good faith. You can’t make stuff up. But within the range of the realistically probable, you have leeway. “Suppose you mow grass for a living, and there was a drought,” Quenga posits. “You can’t control that. There is no penalty if you don’t end up hitting your target.”
Who’s checking your income anyway?
The ACA exchanges do check applicants’ income estimates against data sources such as employer records. In 2019, the Trump administration implemented a rule requiring the ACA exchanges to demand income documentation from applicants who claimed an income above 100% FPL if “trusted data sources” indicated an income below the threshold. If the enrollee failed to provide the documentation, the federal subsidy would be cut off, and the enrollee would likely lose coverage due to the unaffordability of the unsubsidized premiums.
But that rule was challenged in court, and in March 2021 a federal court ordered the Department of Health and Human Services (HHS) to rescind it. HHS responded promptly, rescinding the documentation requirement this past May. HHS did warn that its computer systems could not be retooled instantly, so that for some time, a request for income documentation would be sent in this situation. But HHS added that it would send a follow-up communication to the enrollee, saying that documentation was not required.
The ACA’s creators did not intend to shut poor Americans out of its benefits. But governors and state legislatures that refuse to enact the ACA Medicaid expansion do willfully perpetuate the coverage gap. Low-income people in non-expansion states should use every tool available to produce a good faith income estimate that will give them access to quality government-subsidized health insurance.
* * *
* States that enact the ACA Medicaid expansion offer Medicaid to all legally present adults with household incomes up to 138% FPL. Wisconsin, uniquely, offers Medicaid to adults with incomes up to 100% FPL – which is also the bottom threshold for subsidy eligibility in the private plan marketplace. No one, therefore, is excluded from aid on the basis of income.
Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid. His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic, and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D. in English literature from the University of Rochester.
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Longer enrollment tops list of proposed marketplace improvements
Each year, HHS issues a set of rules and guidelines that apply to the health insurance exchanges created by the Affordable Care Act, and to the health plans that are sold in the individual/family market. The rule-making process includes a proposed rule, a public comment period, and then a final rule. This is normally a fairly straightforward process, but it’s been more complicated for the upcoming 2022 plan year.
The Trump administration issued the proposed 2022 rules in late November last year, and finalized some of them in January, just before inauguration day. In May, the Biden administration finalized the rest of the proposed rule changes, but noted that they intended to propose a new set of rules, with a new public comment period, in order to revisit some of the changes that had been finalized by the outgoing administration.
In late June, the Biden administration published the new proposed rules, and opened a new public comment period that continued through July 28. A total of 341 comments were submitted, and are under review by HHS.
Some of the new proposals are direct reversals of the rule changes that the Trump administration had made. Others are new ideas that are designed to help more people gain access to affordable health insurance. For various provisions, HHS notes that there are pros and cons to the proposals they’re making, and are seeking public feedback before any rules are finalized.
As is always the case, some of the proposed rules are more “behind the scenes” and wouldn’t be particularly noticeable to consumers. But there are some that would directly affect consumers, mostly by making it easier to enroll in health coverage.
How about an extra month of open enrollment?
For the last several years, the standard open enrollment period has been set at November 1 – December 15. This is the schedule that’s used by HealthCare.gov (the exchange/marketplace in 36 states), although Washington, DC and 14 states run their own exchange platforms and most of them tend to extend open enrollment.
HHS has now proposed adding an extra month to open enrollment, so that it would continue through January 15 instead of ending in mid-December. If finalized, this rule change would take effect for the upcoming open enrollment period that starts in November, for coverage effective in 2022.
HHS clarifies that the intent here is to give people more time to enroll, and give enrollment assisters more time to help everyone who needs it. They also point out that some people don’t realize how much their premiums might change from one year to the next, and are caught off guard when they get their invoice in January. By that point, however, it’s normally too late to change plans, and people might end up dropping their coverage altogether if it’s become too expensive. By giving people until January 15 to enroll, there’s time for a “do-over” if a policy was allowed to auto-renew and then ended up being more expensive than expected.
On the other hand, HHS notes that when enrollment ends in mid-December, everyone has full-year coverage, with policies that take effect in January. If enrollment is extended until mid-January, some enrollees will have coverage that takes effect in February instead. Most of the state-run exchanges already offer this, but it would take additional outreach and communication to ensure that consumers are aware that they would still need to enroll by mid-December in order to have coverage in effect as of January 1.
Year-round enrollment for people with income up to 150% FPL
HHS has proposed an ongoing enrollment opportunity for applicants with household income that doesn’t exceed 150% of the federal poverty level. If finalized, this would allow eligible applicants to enroll in coverage at any time of the year. (Under current rules, enrollment outside of the normal open enrollment period requires a special enrollment period, triggered by a qualifying life event).
This enrollment opportunity would be offered through the federally run exchange (HealthCare.gov), and state-run exchanges would have the option to offer it. HHS has clarified that it’s uncertain whether this could be added as an option for the 2022 plan year. It might need to be delayed until 2023 to give health plan actuaries adequate time to prepare for this change.
The American Rescue Plan, enacted earlier this year, has enhanced the ACA’s premium tax credits (premium subsidies) for 2021 and 2022, providing more financial help for people who buy their own health insurance. As a result, households with income up to 150% of the federal poverty level are eligible for subsidies that fully cover the cost of the benchmark plan.
That means they can select either of the two lowest-cost Silver plans and have no monthly premium. (They will also tend to have access to a variety of premium-free Bronze plans, and possibly some premium-free Gold plans. But Silver plans are generally the best option for people in this income range, due to the robust cost-sharing reductions that come with Silver plans.)
HHS notes that the enhanced premium subsidies would help to prevent adverse selection, since most applicants with household income up to 150% of FPL would be able to enroll in Silver plans — with strong cost-sharing reductions — without premiums. This means that they would be unlikely to drop their coverage after receiving medical care, as they would not have to pay anything to keep the coverage in force. (This would be applicable for 2022, assuming the year-round enrollment option could be added for 2022. For 2023 and future years, the availability of zero-premium Silver plans will depend on whether Congress extends the American Rescue Plan’s subsidy enhancements.)
However, HHS does note that some enrollees with income up to 150% of FPL do have to pay at least minimal premiums for the benchmark plan. This includes people in states where additional services beyond essential health benefits are required to be covered (and thus the premium subsidy doesn’t cover the entire cost of the benchmark plan) as well as applicants who are subject to a tobacco surcharge.
And it’s also possible for a person earning up to 150% of FPL to purchase a Silver plan that’s more expensive than the benchmark plan, and thus have a monthly premium even after the subsidy is applied.
It’s possible that there could be some adverse selection among these populations, with enrollees potentially dropping their coverage or shifting to a lower-cost plan after their medical needs are resolved. HHS is seeking public comments about how to best approach this.
It’s worth noting that Medicaid and CHIP enrollment is already available year-round, as is Basic Health Program enrollment in the two states where it’s available. In most states, Medicaid is available to adults under age 65 with household income up to 138% of the poverty level. The income caps are higher for children to qualify for Medicaid, and CHIP is available to children (and in some cases, pregnant women) in many middle-class households.
So a family with low or modest income can obtain coverage year-round in most states — for the children, and possibly the adults. This is true even though many CHIP programs — and some Medicaid programs — charge premiums. Extending open enrollment to run year-round for subsidy-eligible applicants with household income up to 150% of the poverty level would essentially just be an expansion of the enrollment eligibility rules that already exist for lower-income households.
Including the ACA’s expansion of Medicaid, health insurance exchanges, and Basic Health Programs, ACA enrollment now encompasses about 10% of all Americans. But there are still millions of Americans — most of whom have fairly low incomes — who are uninsured and possibly unaware of the financial assistance that’s available to them. HHS is working to make coverage as accessible as possible to this population, and the proposed year-round enrollment window is part of that approach.
Standardized plans return to HealthCare.gov for 2023
Five years ago, HealthCare.gov debuted standardized health plans, dubbed “Simple Choice” plans. The idea was to make it easier for consumers to compare apples to apples when looking at multiple health insurance policy options.
The Trump administration finalized a rule change in 2018 that eliminated Simple Choice plans starting with the 2019 plan year. So HHS did not create standardized plan designs for the last few years.
The 2018 rule change that eliminated standardized plan designs on HealthCare.gov was vacated by a court ruling earlier this year, as were three other provisions of the 2018 rule. So HHS is starting the process of once again creating standardized plans and gathering public feedback on how to best proceed.
And earlier this month, President Biden issued a wide-ranging executive order aimed at promoting competition in the U.S. economy. One of its provisions calls for HHS to “implement standardized options in the national Health Insurance Marketplace and any other appropriate mechanisms to improve competition and consumer choice.”
When standardized plans were previously available in the federally run exchange, it was optional for insurers to offer them and insurers were also free to offer a variety of non-standardized plans. The specifics of their reintroduction are unclear at this point, but the proposed rules seem to indicate that the plans, which are expected to be available for the 2023 plan year, will continue to be optional for insurers.
Consumer protection rules
Some of the other proposed rule changes are designed to protect consumers, although their implementation might not be obvious.
Over the last few years, HHS had implemented several regulatory changes that would have eroded various consumer protections or created confusion in the marketplace. But these rules have either been blocked by the courts or had little in the way of interest from states. And now HHS has proposed a reversal of some of them:
The final version of the new rules is expected to be published within the next few weeks. We won’t know the status of these proposed rule changes until then, but the proposed changes we’ve discussed here are fairly likely to be finalized, albeit with possible modifications based on public comments that HHS received.
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.
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