Issue Briefs | Jun 12, 2012

Overview of Final Regulations on Health Insurance Premium Tax Credit

Manatt Health Solutions

On May 18, 2012, the Internal Revenue Service (IRS) finalized regulations related to health insurance premium tax credits authorized by the Affordable Care Act (ACA) for certain lower-income individuals who enroll in qualified health plans (QHPs) through Exchanges. The tax credit regulations, companion guidance to the Exchange and Medicaid eligibility regulations, finalize policies on eligibility for premium tax credits; provide additional operational details on the calculation of premium tax credits; and clarify and provide additional scenarios on application of these policies. In response to comments on the proposed rule suggesting that premium tax credits may not be available to those individuals who enroll through Federally-facilitated Exchanges (FFE), the preamble to the final rule confirms the availability of premium tax credits to individuals who enroll in QHPs through any of the Exchange models – State-based Exchanges, Partnership Exchanges and FFEs. This brief, prepared by Manatt Health Solutions, provides a walkthrough of the major takeaways from the tax regulations as well as expected future guidance.


Expert Perspectives

CMS Offers New Details on Account Transfer 2.0

The Center for Medicaid and CHIP Services (CMCS) explained the transition to “Account Transfer 2.0” (AT 2.0) in a CMCS Informational Bulletin (CIB) released on October 10, 2024. The CIB indicates significant federal investment in improving the process of transferring consumer application information between state Medicaid and CHIP agencies and the Marketplace in the states using the federal platform. This expert perspective reviews the CIB and highlights opportunities for states to improve account transfer data under the CIB.

CMS Solicits Comments on Medicaid/CHIP Reporting Templates for Mental Health and Substance Use Disorder Parity

On September 9, the Centers for Medicare & Medicaid Services (CMS) released a new collection of federal Medicaid and CHIP reporting templates designed to assist states in monitoring Mental Health Parity and Addiction Equity Act (MHPAEA) compliance in Medicaid and CHIP. Informal public comment is requested by December 2, 2024. This expert perspective reviews the reporting templates to highlight considerations for states and support the formulation of comment submissions.