Family Glitch

Of all the problems the ACA has encountered over the 11 years since it was first signed into law by President Obama, one of the stupidest and most irritating ones had nothing to do with Republican sabotage. The call on this one was made by the IRS (then under the Obama Administration), based on their interpretation of a few bits of language within the legislative text itself back in 2013: The Family Glitch.

As explained by the brilliant Louise Norris:

We still get calls on a regular basis from people who are shopping for individual insurance because adding dependents to their employer plan is prohibitively expensive. We estimate that roughly 20 percent of the people who contact us are in this situation.

Unfortunately, due to a “glitch” in the ACA, they are not eligible for premium subsidies in the exchange if the amount the employee has to pay for employee-only coverage on the group plan is deemed “affordable” – defined as less than 9.78 percent of household income in 2020.

Last Thanksgiving, regular readers may recall that I went on a bit of a rant regarding the annual Notice of Benefit & Payments Parameters, which is a yearly collection of administrative tweaks made by the CMS Administator regarding the specific way in which a slew of ACA policies are actually implemented.

Out of the dozen or so rule changes included in the 2022 NBPP, several of them were perfectly reasonable; several were fairly nominal or neutral...and several of them should have set off red flags everywhere for the incoming Biden Administration, including:

  • Allowing states to flat-out privatize their ACA marketplaces
  • Pushing navigators and assisters to use private, 3rd-party direct enrollment brokers
  • Codifying the Trump Administration's warped interpretation of ACA Section 1332 waivers

There's also a couple of rules in the 2022 NBPP which I opposed, but which won't cause too much damage (at least relative to the three above):

I've written in-depth explainers before of how Silver Loading came into existence and how it works as part of longer blog posts, but I also wanted to have a simpler, standalone version, so here it is.

First, a quick backstory:

Gold Bars

NOTE: This is an updated version of a post from a couple of months ago. Since then, there's been a MASSIVELY important development: The passage of the American Rescue Plan, which includes a dramatic upgrade in ACA subsidies for not only the millions of people already receiving them, but for millions more who didn't previously qualify for financial assistance.

Much has been written by myself and others (especially the Kaiser Family Foundation) about the fact that millions of uninsured Americans are eligible for ZERO PREMIUM Bronze ACA healthcare policies.

I say "Zero Premium" instead of "Free" because there's still deductibles and co-pays involved, although all ACA plans also include a long list of free preventative services from physicals and blood screenings to mammograms and immunizations with no deductible or co-pay involved.

The data below comes from the GitHub data repositories of Johns Hopkins University, except for Utah, which comes from the GitHub data of the New York Times due to JHU not breaking the state out by county but by "region" for some reason.

Important:

  • Every county except those in Alaska lists the 2020 Biden/Trump partisan lean; Alaska still uses the 2016 Clinton/Trump results (the 2020 Alaska results are only available by state legislative district, not by county/borough for some reason...if anyone has that info let me know)
  • I define a "Swing District" as one where the difference between Biden & Trump was less than 6.0%. FWIW, there's just 187 swing districts (out of over 3,100 total), with around 33.7 million Americans out of 332 million total, or roughly 10.2% of the U.S. population.
  • For the U.S. territories, Puerto Rico only includes the case breakout, not deaths, which are unavailable by county equivalent for some reason.

With those caveats in mind, here's the top 100 counties ranked by per capita COVID-19 cases as of Thursday, April 1st, 2021 (click image for high-res version).

  • Blue = Joe Biden won by more than 6 points
  • Orange = Donald Trump won by more than 6 points
  • Yellow = Swing District (Biden or Trump won by less than 6 points)
American Rescue Plan Savings - Family of 4

Last month I posted an explainer with a bunch of colorful graphs & charts explaining how much various households could save thanks to the expanded/enhanced ACA subsidies included with the American Rescue Plan. I included 8 different households, using the national average ACA benchmark plan premium for 2021:

  • Single Adults age 26, 40, 50 and 64
  • Single Parent; Nuclear Family; Empty Nesters w/College-age kid; 60-yr old couple

Here's how much the "Nuclear Family of four" example (40-yr old ocuple with 2 children) would theoretically save, assuming they choose the avg. national benchmark Silver plan:

Breaking via the Washington Healthplanfinder:

Washington Healthplanfinder is extending special enrollment period for Washingtonians seeking health coverage through August 15, 2021

  • More Savings Coming to Washington Healthplanfinder Customers

Due to recent federal action bringing new savings opportunities to current and new individual health insurance market customers, Washington Healthplanfinder is extending the current special enrollment period from May 15 through August 15. This aligns with the recent federal announcement extending the special enrollment period for those using the federal marketplace. This special enrollment period allows currently uninsured individuals, and people both on and off the Exchange, the opportunity to benefit from these new savings.

This morning, Vox reporter Dylan Scott posted a story touting exclusive access to a new ASPE analysis which estimates nearly 7 million uninsured Americans who now qualify for a FREE ($0 premium) ACA health insurance policy, in large part thanks to the American Rescue Plan's expanded subsidies:

Roughly 29 million people currently living in the US lack health insurance. According to the new HHS estimates, about 6.8 million of them could now purchase an ACA plan with no monthly premium, and another 1.3 million could sign up for a health plan that costs less than $50 a month. Many of those people already qualified for free or low-cost coverage prior to the ARP, but based on the federal projections, the new law’s expansion of the ACA made an additional 2 million Americans eligible for free or cheap coverage.

Here's the formal kick-off announcement from HHS Sec. Becerra:

  • An average of three out of five eligible uninsured Americans can access $0 plans after advance payments of tax credits and an average of four out of five current HealthCare.gov consumers will be able to find a plan for $10 or less per month after advance payments of tax credits
  • Department also announces $50 Million Boost to Special Enrollment Period Outreach Campaign

Today, U.S. Department of Health and Human Services (HHS) Secretary Xavier Becerra announced that additional savings and lower health care costs are available for consumers on HealthCare.gov. The American Rescue Plan (ARP) has increased tax credits available to consumers, helping to reduce premiums and giving consumers access to affordable health care coverage.

The Department also announced an additional $50 million in advertising to bolster the Special Enrollment Period outreach campaign. The campaign will run through August 15, 2021.

New Hampshire

A couple of weeks ago I noted that all 11 California health insurance carriers participating on the state's ACA exchange, CoveredCA.com, have agreed not to reset deductibles for current off-exchange enrollees who shift to an on-exchange plan during the ongoing COVID Enrollment Period.

This is a HUGE deal, especially in California, where an estimated 430,000 residents are enrolled in off-exchange ACA policies which are virtually identical to their on-exchange equivalent, with the sole distinction of those enrolled in them not being eligible for ACA subsidies.

With subsidies being beefed up and the 400% FPL subsidy cliff having been killed (for the next 2 years, at least), this means that hundreds of thousands of Californians have just become eligible for thousands of dollars in savings...as long as they transition to the same plan on-exchange.

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