The following information was originally published by Healthcare.gov.
Under the American Rescue Plan of 2021 (ARP), if a taxpayer received or was approved to receive unemployment compensation for any week beginning in 2021, the taxpayer’s household income would be considered to be no higher than 133% of the federal poverty level. If the taxpayer met other eligibility criteria, this means that the taxpayer could be eligible for a premium tax credit that covers the entire premium cost for the benchmark Marketplace plan for the whole household, regardless of the taxpayer’s actual household income amount.
If anyone in the household received or was approved to receive unemployment compensation for any week beginning in 2021, the household may also qualify for cost-sharing reductions (CSRs) if they enroll in a silver-level plan. In both cases households that in the past have not qualified for APTC or CSR due to income below 100% of the federal poverty level (FPL) are considered to have household incomes of 100% FPL for purposes of APTC and/or CSR.
This benefit is available for the remainder of 2021 and consumers who are not currently enrolled in Marketplace coverage and who attest to receiving or being approved to receive unemployment compensation for any week beginning in 2021 can still be eligible for the benefits, and may qualify for a 2021 Special Enrollment Period.
Note: These extra savings aren’t available on 2022 Marketplace plans.
Consumer Impacts for Open Enrollment 2022
Starting with Open Enrollment for 2022, consumers who received these extra Marketplace savings and lower costs in 2021 due to their receipt of unemployment compensation (UC) may notice changes to their financial assistance amounts when they shop and re-enroll for Plan Year (PY) 2022 plans. Their eligibility for financial assistance will be based on their projected household income for 2022, unlike in 2021 when unemployment compensation recipients may have received more financial assistance without regard to their household income amount. However, consumers with household income from 100% through 150% FPL may remain eligible for a tax credit that covers the entire monthly premium cost for the benchmark Marketplace plan and continue to qualify for CSRs.
Other consumers may experience significant changes – such as an increase in their share of the premium or less cost-sharing reductions. For example, consumers who qualified for and accessed the ARP UC benefits in 2021 may experience one of the following situations:
Consumers with incomes above 150% FPL ($39,750 for a family of four) may be eligible for lower APTC and CSR amounts on their PY 2022 plan, meaning their premium and cost sharing owed would be higher.
Consumers with incomes above 250% FPL ($66,250 for a family of four) will no longer be eligible for income-based CSRs on their PY 2022 coverage. Note: Tribal CSR benefits are unaffected.
Consumers with higher incomes may now have to pay the full cost of their Marketplace premium due to being eligible for a $0 APTC amount on their PY 2022 plan. Even though the ARP lifted the 400% FPL income limit for 2021 and 2022, consumers with higher incomes may still not receive a tax credit if the premiums available to them are low enough to be below 8.5% of their household income.
Consumers with household incomes under 100% FPL ($26,500 for a family of four) and who are ineligible for Medicaid (i.e. consumers in the “Medicaid gap”) may now be ineligible for APTC and CSR benefits in PY 2022 due to their household income being under 100% FPL, with the exception of certain immigrant consumers.
Consumers at any income level may see new Data Matching Issues (DMIs) associated with their PY 2022 coverage, and should follow standard processes to submit documents online or via mail to resolve their DMIs.
Messages for consumers
It’s important that consumers who are receiving the ARP UC benefits in 2021 understand those one-time extra savings aren’t available in 2022 and their financial assistance may be changing. Impacted consumers will see special language in their Marketplace Open Enrollment Notice and new content is being added to HealthCare.gov to explain the change. Consumers who don’t return to HealthCare.gov to update their Marketplace application during Open Enrollment and are automatically re-enrolled into PY 2022 coverage will also receive notices with special language that the ARP UC benefits aren’t available for 2022.
Encourage consumers to visit HealthCare.gov to update their Marketplace application, shop for 2022 coverage, and submit any required documents to make sure they’re getting the right coverage and savings.
Open Enrollment for 2022 runs Monday, November 1, 2021–Saturday, January 15, 2022. Enroll by December 15, 2021 for coverage that starts January 1, 2022.
Contact your Cornerstone representative with any questions.