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.
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.