Summary
The American Rescue Plan Act passed both the house and senate and was signed into law by President Biden on March 11, 2021. Many people will focus on the additional stimulus money that will start to be sent in March. However, there are several key changes to share with your customers and members that dramatically improve Marketplace access and affordability. Update: We've provided additional facts about this legislation's impact on subsidies, including a link to the new CMS fact sheet and agent talking points.
Details
Increased Subsidy Amounts And Expanded Access To Subsidies
The American Rescue Plan Act increases the subsidy amounts for all currently subsidy-eligible consumers, and subsidies may now be available for those earning over 400% of the federal poverty level (FPL). You can review the updated FPL job aid here. Update: We're still working through all the details of this legislation, but here are a few important notes. Starting on April 1 for plans with a May 1 effective date two things will be available at SWFL Insurance:
- Increased premium tax credits based on the lower income contribution percentage
- Expanded tax credit access to consumers with household incomes above 400%
This means that new consumers and current enrollees who submit an application and select a plan on or after April 1 will receive the increased premium tax credits for 2021 Marketplace coverage. Current enrollees, including those who recently enrolled through the 2021 Special Enrollment Period, must update their applications and enrollments in order to get new eligibility results starting April 1. They'll need to reselect their current plan in order for the changes to take effect to reduce their premiums for the remainder of the year.
Consumers who need coverage starting April 1 should still apply and select a plan by the end of March through the Special Enrollment Period (SEP) so coverage can start April 1. Then to get the added benefits, they should come back after April 1, your application again, and reselect their current plan to have increased tax credits applied to their coverage for May 1 forward.
Note: Consumers with ACA plans effective April 1, 2021, or earlier, have the choice of waiting until they file their taxes next year in 2022 to receive the additional premium tax credit amount when they file and reconcile their 2021 taxes. However, we recommend all enrollees, after April 1, update their application and review their plan options during the 2021 Special Enrollment Period through May 15 because they may be able to choose a plan with lower out of pocket costs for the same price or less than what they are currently paying.
The updates to the subsidy schedule extend through December 31, 2022. Below are some important changes to note. We will keep you updated as more details of the American Rescue Plan Act are available.
Common Scenarios
| Consumer Scenarios |
Previous Guidance |
American Rescue Plan Changes |
| Subsidy eligible between 100-150% of FPL |
Individuals who make under 133% of the federal poverty level were expected to pay 2% of their income for the benchmark plan. From 133% to 150% it scales up from 3% to 4% of income. |
Are now eligible for a $0 monthly payment the first and second lowest Silver plan in their county. |
| Subsidy eligible FPL between 151% and 399% |
They received premium subsidy based on the cost of the benchmark plan, from 4% to 9.5% Subsidies depend on county, age, and FPL. |
Everyone will receive a larger subsidy. The size of the increase will also depend on county, age, and FPL. Many Bronze options may now be free to consumers. |
| Over 400% of FPL |
Individuals in tax households who were over 400% FPL were not eligible for subsidies. |
Consumers may now have access to subsidies. There is no upper income limit on premium tax credit eligibility, meaning that all middle- and upper-income individuals who purchase their own coverage qualify for a subsidy if their premiums exceed 8.5 percent of their household income. |
| Individual collected or collects at least one unemployment check in 2021 |
Modified Adjusted Gross Income (MAGI) used to determine subsidy and CSR eligibility was calculated the same way for all tax households. |
Consumer is treated as the applicable taxpayer and their tax household is capped at 133% of FPL for the purpose of CSR and subsidy calculation for 2021. |
| Unemployed individuals on COBRA |
Consumers qualify for a SEP for an ACA plan within 60 of losing their group coverage.
Consumers qualify for an SEP within 60 days of COBRA expiring.
A proposed rule that is pending finalization would create a SEP when an employer ends its contribution to COBRA. It is possible that CMS will amend this to include Federal contributions |
Consumers receive a 100% subsidy of COBRA health insurance premiums so unemployed workers can remain on their employer healthcare plans through the end of September 2021. |
What This Means For Members And Consumers
| Members Scenarios |
Situation |
Next Steps |
| Current members who fall into 100-150% FPL and currently have a monthly premium above $0 |
These members' subsidy will equal the premium of the second-lowest cost silver plan. |
Bronze enrollees should buy-up to silver CSR plans. Staying in their current product (HOI vs BCBSFL) will ensure they keep their progress towards their accumulator. Subsidy amounts will update after a person enrolls in a new plan or updates their subsidy application after April 1. The updated subsidy amount will apply to the next month’s bill. CMS should have the subsidies adjusted to reflect the new law by April 1, which means May is the first month where it will be possible to receive an updated subsidy. These members may also be a candidate for an ancillary product, using the reduced monthly premium toward an ancillary premium. |
| Current subsidized members who pay $0. |
These members will not be affected by the changes, but they may be able to buy up to higher value coverage. If they are 150-200% FPL, they will likely want to buy up to CSR silver. Depending on their age, county and income, they may be able to buy up to a richer bronze plan, silver plan, or gold plan and still pay a $0 monthly premium. |
Look for opportunities for these members to switch to a plan with richer benefits. Keep in mind the value of spending towards accumulator when weighing the decision to switch between HOI and BCBSFL after April 1. |
| Current members who are above 150% of the FPL and currently get a subsidy but still pay part of their premium. |
These members will see an increase in subsidy staring the month after they go to the Marketplace or their Florida Blue account and submit an updated eligibility application. |
Subsidy amounts will update after a person enrolls in a new plan or updates their subsidy application after April 1. The updated subsidy amount will apply to the next month’s bill. CMS should have the subsidies adjusted to reflect the new law by April 1, which means May is the first month where it will be possible to receive an updated subsidy. These members may also be a candidate for an ancillary product, using the reduced monthly premium toward an ancillary premium. |
| Current members who do not qualify for a subsidy because they are over 400% of the FPL. |
These members may now qualify for a subsidy. There is no upper income limit on premium tax credits, meaning that all middle- and upper-income individuals who purchase their own coverage qualify for a subsidy if the second-lowest-cost silver premium exceeds 8.5 percent of their overall household income. |
These members should contact their SWFL Insurance agent online or call (800) 829-5270. |
| Unemployment assistance claimants. |
Those who've received at least one unemployment check in 2021 will qualify for APTC and CSR coverage as though their income is capped at 133% FPL. |
CMS has no firm date when the Marketplace will be ready to adjust subsidy to reflect unemployment assistance. We'll provide updates as we have them. Once available, these members will need to complete a new Marketplace application or update their existing one or work with an agent to find all their options and see if they’re eligible to receive subsidies. |
COVID-19 Emergency Special Enrollment Period: Get Covered Florida!
What Is It?
There is a new chance to enroll in a health plan for 2021 coverage! Normally, enrollment in Marketplace (Obamacare) plans ends on December 15. Because of the COVID-19 pandemic, the government has reopened enrollment, and individuals and families can enroll in a plan until May 15. Most people can get help paying the monthly cost of their plan. Some plans are as low as $0 per month1 after financial assistance, depending on income.
Who Qualifies?
Most people living in the U.S. are eligible for this special opportunity to enroll through May 15. And you don't have to be a U.S. citizen to get great coverage. Others who can enroll in plans include:
- Lawful Permanent Resident (LPR) or Lawful Temporary Resident (LTR)
- Cuban/Haitian entrant
- Asylee and Refugee (Eligible if they've been granted employment authorization or are under the age of 14 and have had an application pending for at least 180 days)
- Temporary Protected Status (TPS)
- Work or student visa
What If I Can't Afford It?
- A family of 4 earning up to $104,800/year can qualify for financial help making their monthly payment.
- For 3 out of 4 people in the U.S., the monthly cost of an ACA plan after financial assistance is applied is just $50 per month.
- About 700,000 uninsured Floridians can enroll in a health plan with a $0 monthly cost after financial assistance—and they don't even know it! These plans provide yearly check-ups, vaccines, cancer screenings and other preventive services at no additional cost.
- Knowing all of this, the question is: Can you afford not to check it out?
How Do I Know If I Can Get A Subsidy?
- Many people don't realize they qualify to have all or most of cost of their health plan paid for through a financial assistance from the Marketplace.
- This includes people who lost their job, those who have never had insurance and individuals who tried to enroll in the fall but weren't successful. Everyone now has an opportunity to get covered.
- Plans and pricing change each year, so if you thought health coverage was not affordable in the past, be sure to check again. You may be surprised to find more affordable options are now available.
- To see if you qualify, you can contact an SWFL Insurance agent online for help, or call (800) 829-5270.
Where Can I Find More Information?
You can visit here to learn about how health coverage works and why it's important. That website is for education—not sales—and there's information you can download and share, if you'd like. Then, when you're ready to enroll, turn to SWFL Insurance.
Don't wait! Your coverage will start the first of the month after you enroll. Enrollment ends May 15!
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