CMS Premium Rebate Guidance – Implications for States and Other Stakeholders
On August 4, 2020, CMS released guidance permitting health insurance issuers to provide certain premium rebates for 2020. The guidance explains the conditions rebates must meet and clarifies the impact of individual market rebates on ACA provisions like the premium tax credit. The guidance provides welcome news about the impact of rebates on consumers, but it may pose challenges for issuers that have already been providing rebates. This piece summarizes the guidance, explains how it affects key stakeholders, and notes some questions that remain unanswered.