Building on Year One 1095-A Form Success: Marketplaces’ Recommendations for Future Tax Seasons
Elizabeth Osius, Jocelyn Guyer, and Joel Ario, Manatt Health Solutions
Tax year 2014 marked the first year during which all health insurance marketplaces were required to report information about Advance Premium Tax Credits (APTCs) to enrollees through Form 1095-A, which was developed by the Internal Revenue Service (IRS) and used by enrollees to fill out new tax forms. In order to address potential concerns leading up to the execution of this process, the State Network convened a workgroup of states, led by Manatt Health Solutions, which enabled discussion of implementation challenges and solutions. Many of the expected challenges associated with this process were addressed in advance, allowing the marketplaces to provide most forms in a timely fashion and develop solutions to challenges as they arose. This issue brief, prepared by Manatt Health Solutions, builds on the workgroup discussions, as well as follow-up interviews with marketplace officials in several states, to examine practical strategies learned this year to ease implementation of 1095-A forms in the future, and also to assist carriers, government agencies, and employers facing new ACA tax reporting requirements for tax year 2015.
On December 6, the Centers for Medicare & Medicaid Services published and made effective an interim final rule (IFR) with comment period regarding states’ ongoing unwinding efforts to redetermine eligibility for all Medicaid enrollees nationwide. This expert perspective summarizes the IFR, which interprets and implements the state reporting requirements and CMS enforcement authorities that Congress enacted last winter in the Consolidated Appropriations Act of 2023.
The 11th annual open enrollment period (OEP) is underway, providing consumers with an opportunity to enroll in health coverage for plan year 2024 through the Affordable Care Act Marketplaces. To support consumers during this OEP, State-Based Marketplaces (SBMs) are innovating to make health coverage more affordable and easier for consumers to enroll. This expert perspective highlights new initiatives being implemented by SBMs during the plan year 2024 OEP, including establishing or improving state subsidy programs to reduce out-of-pocket costs, expanding coverage for undocumented populations, or implementing policies to improve the enrollment process.
As the unwinding of the Medicaid continuous coverage requirement continues, both states and the federal government are tracking and monitoring the impacts of the resumption of eligibility redeterminations and disenrollments. Given the time-lags and caveats of CMS data, many states are publishing their own state data dashboards. To date, 46 states (including the District of Columbia) have released unwinding data in either an interactive dashboard or static pdf format, or are making public their required CMS Monthly Unwinding Data reports. This expert perspective includes an interactive map with links to state reporting, as well as a table tracking the unwinding indicators and disaggregated data that states are reporting on. SHVS will continue to update this EP as more states publish their unwinding data.