On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (the ARP), a wide-ranging package of health care and economic measures responding to the coronavirus pandemic. The ARP includes a broad expansion of the Affordable Care Act’s (ACA) main health insurance subsidy, the premium tax credit (PTC), the first major expansion of the health care reform law since its passage. This piece highlights the policymaking considerations that states must account for in light of the PTC expansion and uncertainty about future federal action. A key theme that emerges is that states will benefit from approaches that give them the flexibility to adjust policies year by year as the federal landscape develops.
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.