APTC

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:

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.

UPDATE: Everything below refers to HR 369, but the American Rescue Plan, HR 1319, contains a virtually identical expansion of ACA subsidies...if only for two years.

Note that under HR 1319 (AmRescuePlan), the first year would be retroactive, meaning that current ACA enrollees should receive additional subsidies dating back to January 2021, though I don't know what form that will take...rebate checks, credit towards future premiums or an extra tax refund next spring.

Over the past couple of years, one of the things I've become known for is my obsessive fixation on visually displaying how much various households would save on healthcare premiums if various ACA subsidy-boosting bills were passed compared with the current ACA subsidy structure.

Back on January 14th, I noted that President Biden's proposed $1.9 trillion American Rescue Plan includes a couple of interesting ACA-specific provisions:

Roughly two to three million people lost employer sponsored health insurance between March and September, and even families who have maintained coverage may struggle to pay premiums and afford care. Further, going into this crisis, 30 million people were without coverage, limiting their access to the health care system in the middle of a pandemic. To ensure access to health coverage, President-elect Biden is calling on Congress to subsidize continuation health coverage (COBRA) through the end of September. He is also asking Congress to expand and increase the value of the Premium Tax Credit to lower or eliminate health insurance premiums and ensure enrollees - including those who never had coverage through their jobs - will not pay more than 8.5 percent of their income for coverage.

Together, these policies would reduce premiums for more than ten million people and reduce the ranks of the uninsured by millions more.

Note: This is the second or third time that I'm cribbing a bit from my friend & colleague Andrew Sprung over at Xpostfactoid. If you like my healthcare policy analysis/writing style and follow me on Twitter, you should follow him at @xpostfactoid as well.

Over at Xpostfactoid, Andrew Sprung beat me to the punch by several days with an excellent two-part look at the "ACA 2.0 Hunger Games" scenario.

During the Democratic primary season, I posted a simple graph which boiled down the four major types of healthcare policy overhaul favored by the various Democratic Presidential candidates...which also largely cover the gamut of systems preferred by various Democratic members of the House and Senate.

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