APTC

NOTE: SEE SUMMARY TABLE IN UPDATE ALL THE WAY AT THE END.

I'm doing my best to stop myself from putting my head through a wall this weekend.

You may have seen this viral tweet making the rounds over the past day or so:

The Democrats just spent $52 billion to subsidize COBRA for 1.3 million people until September. That’s $40k per person for less than 6 months of health insurance. Most countries spend about $5-6k per person per year for universal healthcare.

— cabral (@axcomrade) March 12, 2021

This was posted at 12:22pm on Friday, March 12th, 2021. It's still live as of 11:00am on Sunday the 14th, has over 32,700 Likes and has been retweeted over 7,300 times as of this writing, but in case it's deleted by the time you read this, here's a screen shot:

HealthCare.Gov Logo

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

President Biden

Yesterday I wrote a long, wonky post about an unusual case involving a legally-present (green card), unemployed Nigerian immigrant.

The short version is that because his income is so low, he normally wouldn't be eligible for ACA subsidies...except because he lives in Maryland, a Medicaid expansion state, he would normally be eligible for Medicaid...except that because he's an immigrant who's been in the United States for less than five years, he isn't eligible for Medicaid...except that, thanks to an obscure provision baked into the Affordable Care Act, he is eligible for ACA subsidies after all!

‘(B) SPECIAL RULE FOR CERTAIN INDIVIDUALS LAWFULLY PRESENT IN THE UNITED STATES.—If—

‘‘(i) a taxpayer has a household income which is not greater than 100 percent of an amount equal to the poverty line for a family of the size involved, and

 

During the early days of the Affordable Care Act (and again during the insane "Repeal/Replace" saga of 2017), one of the dumbest and most disingenuous talking points of Republicans was to attack the ACA for being "too long."

I'm quite serious...many Very Serious Conservatives stroked their beards and wrung their hands over the sheer length of the ACA's legislative text (officially around 2,700 pages, though if you includ the mountain of regulations which are included with any major bill impacting hundreds of millions of people it could theoretically be tracked at 20,000 pages or so).

This silliness was most clearly expressed by Donald "Who?" Trump's first press secretary, Sean Spicer, who infamously put a copy of the House Republican's "replacement plan" (the AHCA) next to a copy of the ACA itself and cited the difference in pages between the two as some sort of "proof" that the AHCA was "better" for reasons unknown.

Anyway, the AHCA, Sean Spicer and Donald Trump are now gone, good riddance.

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.

Get Covered 2021!

 

Nearly every state (+DC) has re-opened enrollment on their respective ACA exchanges in response to both the ongoing COVID-19 pandemic and the American Rescue Plan (ARP), which substantially expands and enhances premium subsidies to millions of people!

If you've never enrolled in an ACA healthcare policy before, or if you looked into it years ago but weren't impressed, please give it another shot now. Thanks to the ARP (and some other reasons), it's a whole different ballgame this spring & summer.

Here's 10 important things to understand when you #GetCovered:

If you look at the actual legislative text of the final version of the Patient Protection & Affordable Care Act (PPACA, or simply ACA), the table describing the applicable maximum percentage of income that exchange-based enrollees have to pay for their premiums looks like the table below:

(Notably missing is the lower-bound 100% FPL subsidy eligibility cut-off; there's a separate section of the law which notes the 100% threshold but makes an exception for certain lawfully-present immigrants who earn less than 100% FPL but who aren't eligible for Medicaid for various reasons and are given an exception).

 

Over at the Journal of Healthcare Finance, David Anderson, Sih-Ting Cai and Jean Marie Abraham have published an interesting idea which I've never thought about before:

In 2019, CMS (2020b) began publishing its Quality Rating System (QRS) for incumbent insurers who sell qualified health plans in the individual market. This information includes scores for medical care, member experience, and plan administration which are then rolled up into an overall, global quality rating (GQR). Recent research has shown notable variation by plan characteristics for behavioral health quality (Abraham, et al., 2021) and plan administration scores (Anderson, et al., 2020). CMS hopes this information is used by consumers to make enrollment decisions.

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.

*(Yes, believe it or not, I was able to come up with an extreme example of an older couple in Oklahoma managing to save a jaw-dropping $64,000/year in heath insurance premiums if the American Rescue Plan is passed, signed and implemented.)

When President Biden announced that HealthCare.Gov would be re-launching an extended Special Enrollment Period in light of the ongoing COVID-19 pandemic, I wasn't surprised at all; in fact, I would have been shocked if he hadn't ordered the HHS Dept. to do so. I was surprised by how long the new COVID Enrollment Period would be: A full 3 months (I had been expecting either 30, 45 or perhaps 60 days at the outside).

The more I thought about it, however, I realized three good reasons to re-open HC.gov all the way out until mid-May. The first two I already wrote about several weeks ago:

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