In the absence of federal legislation, states are actively seeking tools to reform their health care systems. While 1115 waivers rightly get a lot of attention, because of their ability to reshape state Medicaid programs, the Affordable Care Act’s Section 1332 waivers continue to be a promising avenue for states to stabilize their health insurance marketplace. SHVS is tracking state activity and has many resources, including a template, for states interested in pursuing a Section 1332 waiver.
Advance Premium Tax Credit Reconciliation Questions and Answers
Melinda Dutton, Jocelyn Guyer and Tanya Schwartz, Manatt Health Solutions
Under the Affordable Care Act (ACA), individuals seeking health insurance coverage through a Marketplace are assessed for eligibility for an advance payment of the premium tax credit (APTC) based on projected annual income. When eligible individuals file federal income taxes at the end of the year, the Internal Revenue Service (IRS) will reconcile the premium tax credit received based on estimated annual income with what should have been received based on actual income. In many instances, projected annual income may differ from actual income, which can result in a refundable credit or the need to pay back excess premium tax credits. This issue brief, prepared by Manatt Health Solutions, presents specific scenarios and addresses questions raised by states about the federal requirements that apply to premium tax credit eligibility when actual income at year-end differs from projected annual income.