Up the Subs

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The Centers for Medicare & Medicaid Services (CMS) has just sent out guidance about how the newly-expanded & enhanced subsidies will work for those currently enrolled in (or newly enrolling in) healthcare policies via the federal ACA exchange, HealthCare.Gov.

It's important to note that the following guidelines only apply to residents of the 36 states hosted via HC.gov. The timing, policy and procedures for the new/expanded subsidies for residents of the 15 states which operate their own ACA exchanges may vary.

With that in mind, here's how CMS says things will work via HealthCare.Gov.

The first section is mostly just an overview of the ARP and a refresher on how ACA subsidies are calculated...

American Rescue Plan and the Marketplace

The New Law

My biggest takeaway from the press releases below is that everyone will be made whole (that is, those eligible for additional subsidies or newly-eligible for subsidies at all will receive them in full), but that it may take anywhere from a few weeks to several months for that to happen, so cool your jets.

Covered California:

Covered California Hails the Signing of the American Rescue Plan Which Will Benefit Millions

SACRAMENTO, Calif. — Covered California’s executive director, Peter V. Lee, issued this statement following President Joe Biden’s signing of the American Rescue Plan. The landmark legislation provides new financial help to people who receive their health insurance through Affordable Care Act marketplaces like Covered California. The measure will lower health care costs by providing new and expanded subsidies to more Americans than ever before.

In early February, I posted a deep dive into HR 369, the Health Care Affordability Act, and how it would reduce net ACA premiums by permanently eliminating the income "subsidy eligibility cliff" (#KillTheCliff) and making the underlying subsidy formula more generous for all enrollees (#UpTheSubs).

I'm re-posting an updated, modified version of this analysis for two reasons:

  • First, because HR 1319, the American Rescue Plan, is about to actually pass and be signed into law, with a slightly different formula from HR 369 embedded within it (if only for two years).
  • Second, because my earlier analysis also threw in two other subsidy enhancement tables which confused the issue (California's state-based subsidies, and the predecessor to HR 369, both of which are/were less generous)

In this version I'm using the actual Advanced Premium Tax Credit (APTC) table under the American Rescue Plan, and I'm cutting out all references to the other two tables to avoid confusion.

This afternoon, the Congressional Budget Office released their 10-year "score" report of the largest single chunk of the House Democrats version of the American Rescue Plan from the Ways & Means Committee:

Legislation Summary

S. Con. Res. 5, the Concurrent Resolution on the Budget for Fiscal Year 2021, instructed several committees of the House of Representatives to recommend legislative changes that would increase deficits up to a specified amount over the 2021-2030 period. As part of this reconciliation process, the House Committee on Ways and Means approved legislation on February 10 and 11, 2021, with a number of provisions that would increase deficits. The legislation would extend unemployment benefits, establish a pandemic emergency fund, increase subsidies for health insurance, provide cash payments to eligible people, expand several tax credits, and modify rules for pensions, among other provisions designed to mitigate the impact of the COVID-19 pandemic caused by the coronavirus.

Earlier this evening, the House Ways & Means Committee formally published the markup of nine legislative provisions which, if they all survive the process, will make up roughly half of President Biden's proposed $1.9 trillion COVID-19 relief package, aka the American Rescue Plan:

The Ways and Means’ proposals comprise half of the $1.9 trillion Democratic COVID-19 relief package

SPRINGFIELD, MA – Today, House Ways and Means Committee Chairman Richard E. Neal (D-MA) announced the Committee will consider nine legislative proposals under the budget reconciliation instructions this week as the next step in delivering COVID-19 relief to the American people. Beginning on Wednesday, February 10, 2021 at 10:00 a.m. through Friday, February 12, 2021, the Committee will markup proposals spanning from extending unemployment insurance to expanding the child tax credit to delivering another round of direct assistance to struggling Americans.

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