Health Issues

The COVID-19 pandemic has cast a spotlight on the importance of the various safety net systems that the U.S. has in place. Medicaid is a prime example: As of July 2021, enrollment in Medicaid/CHIP exceeded 83.6 million people, with more than 12 million new enrollees since early 2020.

This enrollment growth — more than 17% in 17 months — is obviously tied to the widespread job and income losses that affected millions of Americans as a result of the COVID pandemic. Fortunately, Medicaid was able to step in and provide health coverage when people lost their income; without it, millions of additional Americans would have joined the ranks of the uninsured. We didn’t see that happen in 2020, thanks in large part to the availability of Medicaid and CHIP.

But the continued enrollment growth in Medicaid is primarily due to the fact that the Families First Coronavirus Response Act (FFCRA), enacted in March 2020, provides states with additional federal funding for their Medicaid programs, as long as they don’t disenroll people from Medicaid during the COVID public health emergency (PHE) period. And all states accepted the additional federal Medicaid funding.

So while there is normally quite a bit of turnover in the Medicaid program — with some people losing eligibility each month — enrollment has trended upward for nearly two years, without the normal disenrollments that were routine prior to the pandemic.

But the PHE will eventually end — possibly in mid-April — and millions of Americans could lose their Medicaid coverage soon thereafter. There are very real concerns that many people who are actually still eligible for Medicaid might lose their coverage due to onerous paper-based eligibility redetermination systems.

We’re hopeful that states will work to make the redeterminations and renewals process as transparent, accurate, and simple as possible. But our goal today is to help you understand what you need to know in order to maintain coverage if you’re one of the millions of people who could potentially lose Medicaid eligibility in the coming months.

• If you have access to an employer-sponsored health plan, your loss of Medicaid coverage will trigger a special enrollment period that will allow you to enroll in the employer-sponsored plan. This window is only required to be 30 days, so don’t put this off.
• If you do not have access to an employer-sponsored health plan, you can apply for a premium tax credit (subsidy) to offset the cost of coverage in the health insurance marketplace in your state. Depending on your income, you might also qualify for cost-sharing reductions (CSR), which will make your out-of-pocket costs more affordable as long as you select a Silver-level plan (you can use premium subsidies with plans at any metal level, but CSR benefits only come with Silver plans).
• The window to enroll in a marketplace plan will start 60 days before your Medicaid coverage ends, and will continue for 60 days after it ends. But in order to have seamless coverage, you’ll need to submit your application before your Medicaid ends. Your new marketplace plan cannot have a retroactive effective date and won’t take effect until at least the first of the month after you apply. So you’ll have a gap in coverage if you submit your marketplace application after your Medicaid coverage has terminated.
• The subsidies that are currently available in the marketplace are particularly generous, thanks to the American Rescue Plan, and you might be pleasantly surprised to see how affordable the coverage will be. The enhanced subsidies (ie, even better than the Affordable Care Act’s original subsidies) will remain in place through the end of 2022 — and Congress might extend them for future years (even if they don’t, the regular ACA subsidies will continue to be available after 2022).

The main point to keep in mind is that the opportunity to transition to new coverage, from an employer or through the marketplace, is time-limited. If you miss your special enrollment period, you’ll have to wait until the next annual open enrollment period to sign up for coverage (in the individual market, that starts November 1; employers set their own enrollment windows).

There is a new special enrollment period that allows people with household income up to 150% of the poverty level to enroll in coverage year-round, for as long as the enhanced subsidies remain in place (so at least through the end of 2022, and possibly longer).

For people whose income has increased enough to make them ineligible for Medicaid, but still eligible for this special enrollment period, there will be more flexibility in terms of access to coverage. But although HHS finalized this special enrollment period in September 2021, it won’t be available on HealthCare.gov (and enhanced direct enrollment partner websites) until late March 2022 (it’s available prior to that for people who call the HealthCare.gov call center and enroll via phone). The new low-income special enrollment period is optional for the 18 state-run exchanges, although several of them had already made it available as of February (Colorado, Pennsylvania, New Jersey, California, Maine, and Rhode Island). More are likely to follow suit once it debuts on HealthCare.gov.

But it’s still in your best interest to submit an application as soon as possible, even after the new low-income special enrollment period becomes widely available. Free or nearly free coverage will be available in the marketplace for people eligible for this special enrollment period (this is a result of the American Rescue Plan’s subsidy enhancements). And since coverage cannot be backdated, it’s essential to ensure that you’re covered before any medical needs arise.

So the best course of action is to simply enroll in a marketplace plan as soon as you know that your Medicaid coverage will be terminated (assuming you don’t have access to an employer-sponsored plan), in order to avoid any gap in coverage. This is true regardless of whether you’ll qualify for the new low-income special enrollment period, since you’ll have a normal loss-of-coverage special enrollment period when your Medicaid ends, and you can take advantage of it right away.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

Most People in america under the age of 65 get their health insurance policy from an employer. This helps make lifestyle relatively basic as very long as you have a work that provides sound wellbeing gains: All you will need to do is enroll when you are suitable, and if your employer offers a couple of possibilities from which to choose, decide the 1 that greatest matches your desires just about every 12 months during your employer’s annual enrollment period of time.

But the draw back to obtaining health and fitness insurance policies joined to work is that shedding your position will also signify dropping your wellness insurance policies, adding tension to an already demanding condition.

The very good news is that you’ve received selections — probably various, based on the instances. Let’s just take a glimpse at what you need to know about wellbeing insurance coverage if you’ve dropped your career and are going through the decline of your employer-sponsored overall health protection.

Open enrollment for 2022 health and fitness insurance policies operates by at least January 15, in most states. But if you are getting rid of your occupation-centered health insurance policy soon after that, you do not have to wait for the next annual open enrollment interval to indication up for a new ACA-compliant program. You are going to qualify for your very own exclusive enrollment period of time owing to the reduction of your employer-sponsored wellness strategy.

This will allow for you to enroll in a program via the market/exchange and acquire benefit of the subsidies that are larger than at any time, thanks to the American Rescue Prepare.

If you enroll prior to your coverage reduction, your new system will acquire influence the first of the thirty day period immediately after your old approach ends, which indicates you are going to have seamless coverage if your old system is ending on the past working day of the thirty day period.

Your distinctive enrollment time period also continues for 60 times following your protection reduction, despite the fact that you’d have a gap in coverage if you wait around and enroll right after your previous prepare finishes, given that your new prepare wouldn’t take result retroactively.

If you’re in that condition, you may well uncover that a quick-term health strategy is a great solution for bridging the hole right up until your new approach can take outcome. Brief-time period plans won’t cover pre-existing disorders and are not regulated by the Reasonably priced Care Act (ACA). But they can give relatively fantastic protection for sudden healthcare demands through a temporary window when you’d normally be uninsured.

Alternatively, if COBRA is out there, you have 60 days to make your mind up whether or not you want to just take it or not. You can use this window as a little bit of a cushion between your outdated protection and your new coverage, simply because COBRA will take influence retroactively if and when you elect to use it. So if you are going to have a 1-thirty day period gap in between your job approach ending and your new plan starting, you could elect COBRA if you close up with healthcare wants in the course of that month. The protection would seamlessly begin when your aged strategy would have finished, staying away from any hole in protection as prolonged as you pay out all COBRA rates that are because of.

If COBRA (or point out continuation coverage) is out there, your employer will notify you and give you details about what you’ll require to do to activate the coverage continuation, how prolonged you can hold it, and how significantly you’ll have to pay back each thirty day period to hold the coverage in power.

If you depend on COBRA after leaving your career (as a substitute of transitioning to a self-purchased prepare in the marketplace), you are going to have a unique enrollment time period when the COBRA subsidy ends. This will permit you to transition to an specific/household prepare at that place if you want to.

• ACA market subsidies are now offered at all income concentrations, dependent on the value of protection in your area (the American Rescue Strategy eliminated the income cap for subsidy eligibility for 2021 and 2022). And the subsidies are sizeable, masking the greater part of the high quality value for the majority of marketplace enrollees. Unless your employer is subsidizing your COBRA protection, you are going to likely come across that the month-to-month premiums are decrease if you enroll in a prepare by means of the market, as opposed to continuing your employer-sponsored program.
• Have you already spent a substantial volume of revenue on out-of-pocket prices underneath your employer-sponsored approach this yr? You’ll almost absolutely be commencing over at $ if you switch to an specific/relatives program, even if it is supplied by the exact same insurance company that offers your employer-sponsored coverage. Based on the details of your circumstance, the revenue you have presently compensated for out-of-pocket medical costs this year could offset the decreased premiums you’re probable to see in the marketplace.
• Do you have specified medical practitioners or professional medical amenities you have to have to go on to use? You will want to thoroughly check the service provider networks of the readily available individual/loved ones ideas to see if they are in-network (provider networks can vary considerably between the employer-sponsored and specific marketplace, even if the programs are provided by the exact insurance policy company). And if there are specific remedies that you require, you are going to want to be absolutely sure they’re on the formularies of the strategies you’re looking at.
• Will you qualify for a quality subsidy if you swap to an individual/family members prepare? If you do qualify, you will require to store in your exchange/market, as subsidies are not accessible if you acquire your approach instantly from an coverage corporation. (You can contact the range at the major of this webpage to be related with a broker who can aid you enroll in a plan by the exchange.) And again, as a final result of the ARP, subsidies are larger sized and extra widely available than normal that will carry on to be the situation throughout 2022 as properly.

What if my income is far too lower for subsidies?

In get to qualify for premium subsidies for a program procured in the market, you have to not be qualified for Medicaid, quality-absolutely free Medicare Portion A, or an employer-sponsored approach, and your revenue has to be at minimum 100% of the federal poverty level.

In most states, the ACA’s expansion of Medicaid eligibility presents protection to older people with home cash flow up to 138% of the poverty stage, with eligibility decided centered on present monthly revenue. So if your profits has quickly dropped to $, you are going to most likely be qualified for Medicaid and could changeover to Medicaid when your position-centered protection ends.

Sadly, there are nonetheless 11 states in which most older people facial area a coverage gap if their house profits is beneath the federal poverty level. They aren’t qualified for premium subsidies in the market, and also are not eligible for Medicaid. This is an unfortunate scenario that all those 11 states have established for their low-cash flow inhabitants. But there are approaches for avoiding the coverage gap if you’re in a person of people states.

And maintain in mind that subsidy eligibility in the marketplace is dependent on your household cash flow for the entire year, even if your existing every month income is beneath the poverty amount. So if you gained plenty of before in the calendar year to be subsidy-suitable, you can enroll in a program with subsidies based mostly on that revenue, regardless of the truth that you may possibly not get paid just about anything else for the relaxation of the 12 months.

There has been an increase not too long ago in the quantity of individuals retiring in their late 50s or early 60s, right before they are suitable for Medicare. The ACA created this a extra sensible option starting in 2014, thanks to top quality subsidies and the elimination of health-related underwriting.

And the ARP has boosted subsidies and manufactured them additional widely available by means of the finish of 2022, producing affordable coverage more available for early retirees. That is specifically accurate for those whose pre-retirement earnings may well have designed them ineligible for subsidies in the yr they retired, thanks to the “subsidy cliff” (which has been eliminated by the ARP by way of the end of 2022).

So if you’re getting rid of your job or picking out to leave it and you continue to have a few months or a couple of many years before you are going to be 65 and qualified for Medicare, rest assured that you will not have to go uninsured.

You will be ready to indication up for a market strategy throughout your distinctive enrollment period induced by the reduction of your employer-sponsored plan. And even if you gained a pretty sturdy profits in the earlier component of the year, you may continue to qualify for top quality subsidies to offset some of the cost of your new prepare for the rest of the 12 months.

And market programs are normally procured on a month-to-thirty day period foundation, so you will be ready to terminate your protection when you at some point changeover to Medicare, irrespective of when that comes about.

Really don’t be concerned, get coated

The small tale on all of this? Coverage is obtainable, and obtaining your personal wellbeing strategy isn’t as challenging as it could possibly appear to be at first glance, even if you’ve had employer-sponsored protection all your lifestyle.

You can signal up outdoors of open up enrollment if you’re dropping your job-based mostly insurance, and there is a superior opportunity you’ll qualify for money help that will make your new prepare affordable.

You can master much more about the marketplace in your state and the obtainable program solutions by deciding upon your state on this map. And there are zero-expense enrollment assisters – Navigators and brokers – offered throughout the region to assist you make sense of it all.

Louise Norris is an personal well being insurance policies broker who has been crafting about wellness insurance policies and wellness reform given that 2006. She has penned dozens of viewpoints and academic pieces about the Reasonably priced Treatment Act for healthinsurance.org. Her point out health and fitness trade updates are frequently cited by media who protect wellness reform and by other well being coverage gurus.

The Biden administration announced last week that enrollment in ACA marketplace plans had reached an all-time high of 13.6 million* as of December 15, with a month still to go in the open enrollment period (OEP) for 2022 in most states.

That’s an increase of about 2 million (17%) over enrollment as of the same date last year, according to Charles Gaba’s estimate, and well above the previous high of 12.7 million recorded as of the end of open enrollment for 2016, which lasted until January 31 in most states. When OEP ends this coming January, enrollment in marketplace plans will exceed 14 million.

In the 33 states using the federal exchange, HealthCare.gov (for which the federal government provides more detailed statistics than in the 18 state-based exchanges), almost all enrollees (92%) received premium tax credits (subsidies) to help pay for coverage – including 400,000 who would not have qualified for subsidies prior to passage in March of this year of the American Rescue Plan (ARP). That bill not only increased premium subsidies at every income level through 2022, but also removed the previous income cap on subsidies, which was 400% of the federal poverty level (FPL) ($51,520 per year for an individual and $106,000 for a family of four). In 2022, no enrollee who lacks access to other affordable insurance pays more than 8.5% of income for a benchmark Silver plan (the second cheapest Silver plan in each area), and most pay far less.

The enrollment increase is tribute to the huge boost in affordability created by the ARP subsidies. A benchmark Silver plan with strong Cost Sharing Reduction (CSR, attached to Silver plans for low-income enrollees) is now free at incomes up to 150%FPL ($19,320 for an individual, $39,750 for a family of four in 2022) and costs no more than 2% of income ($43/month for an individual) at incomes up to 200% FPL. The percentage of income required for the benchmark Silver plan  was reduced at higher incomes as well.  The ARP also provided free high-CSR Silver coverage to anyone who received any unemployment insurance income in 2021.

The enrollment gains during OEP build on the enrollment surge triggered by the emergency special enrollment period (SEP) opened by the Biden administration on February 15 of this year, which ran through August 15 in the 33 states using HealthCare.gov, and for varying periods in the 15 states that ran their own exchanges in 2021. (There are now 18 state-based exchanges, as Kentucky, Maine and New Mexico launched new ones for 2022.)

The ARP subsidies came online in April (or May in a few state marketplaces). From February to August, 2.8 million people enrolled during the SEP, and total enrollment increased by 900,000 on net from February to August (as people also disenrolled every month, and many enrollees doubtless regained employer-sponsored coverage during a period of rapid job growth).

In addition, once the ARP subsidy increases went into effect, 8 million existing enrollees saw their premiums reduced by an average of 50%, from $134 to $67 per month. Enrollees’ premiums in 2022 should be similar to those of the SEP.

Enrollment increases during open enrollment – as during the SEP and the OEP for 2021 – were heavily concentrated in states that have not enacted the ACA expansion of Medicaid eligibility. There were 14 such states during most of the SEP and 12 during the (still current) OEP, as Oklahoma belatedly enacted the Medicaid expansion starting in July of this year, and Missouri in October.

In non-expansion states, eligibility for ACA premium subsidies begins at 100% FPL, while in states that have enacted the expansion, marketplace subsidy eligibility begins at 138% FPL, and Medicaid is available below that threshold. In non-expansion states, the marketplace is the only route to coverage for most low-income adults, and those who report incomes below 100% FPL mostly get no help at all – they are in the notorious coverage gap. In those states, about 40% of marketplace enrollees have incomes below 138% FPL – that is, they would be enrolled in Medicaid if their states enacted the expansion.

During OEP, these 12 non-expansion states account for 81% of the enrollment gains in the 33 HealthCare.gov states, and about two-thirds of enrollment gains in all states. The table below also shows gains over a two-year period, encompassing the effects of the COVID-19 pandemic.

In the 39 states that have enacted the ACA Medicaid expansion (21 on HealthCare.gov and 18 running their own exchanges), far fewer enrollees are eligible for free Silver coverage. In expansion states, eligibility for marketplace subsidies begins at an income of 138% FPL, as people below that threshold are eligible for Medicaid. Nevertheless, enrollment growth in non-expansion states during the current OEP is substantial, increasing by about 755,000 year-over-year, or 13%.

The marketplace has been a bulwark against uninsurance during the pandemic, among low-income people especially and in the non-expansion states in particular. As shown in the chart above, enrollment in these 11 states increased by 1.8 million from Dec. 15, 2019 to Dec. 15, 2021 – a 37% increase. For all states, the two-year increase is in the neighborhood of 25% and will approach 3 million (from 11.4 million in OEP for 2020 to above 14 million when OEP for 2022 ends in January). That’s in addition to an increase of more than 12 million in Medicaid enrollment during the pandemic.

While millions of Americans lost jobs when the pandemic struck, and millions fewer are employed today than in February 2020, the uninsured rate did not increase during 2020, according to government surveys, and may even prove to have downticked during 2021 or 2022 when the data comes in.

While the government has not yet published detailed statistics as to who has enrolled during the current OEP, they did do so in the final enrollment report for the emergency SEP. During the emergency SEP, out of 2.8 million new enrollees, 2.1 million were in the 33 HealthCare.gov states. In those states, 41% of enrollees obtained Silver plans with the highest level of CSR, which means that they had incomes under 150% FPL (or received unemployment income) and so received free coverage in plans with an actuarial value of 94% – far above the norm for employer-sponsored plans.

The median deductible obtained in HealthCare.gov states was $50, which makes sense, as 54% of enrollees obtained Silver plans with strong CSR, raising the plan’s actuarial value to either 94% (at incomes up to 150% FPL) or to 87% (at incomes between 150% and 200% FPL). Two-thirds of enrollees in HealthCare.gov states paid less than $50 per month for coverage, and 37% obtained coverage for free.

At higher incomes, as noted above, 400,000 enrollees who received subsidies in HealthCare.gov states would not have been subsidy-eligible before the ARP lifted the income cap on subsidies (previously 400% FPL). The same is also doubtless true for several hundred thousand enrollees in state-based marketplaces. The SBEs account for a bit less than a third of all enrollment, but in those states, all of which have expanded Medicaid, the percentage of enrollees with income over 400% FPL is almost twice that of the HealthCare.gov states (12% versus 7% during the emergency SEP).

Marketplace subsidies are based on an estimate of future income. For low-income people in particular, who are often paid by the hour, work uncertain schedules, depend on tips, or are self-employed, income can be difficult to project. The desire to be insured during the pandemic may have spurred some applicants to make sure their estimates cleared the 100% FPL threshold. (Enrollment assisters and brokers can help applicants deploy every resource to meet this goal.)

For OEP 2022, the Biden administration raised funding for nonprofit enrollment assistance in HealthCare.gov states to record levels, enough to train and certify more than 1,500 enrollment navigators. This past spring, in compliance with a court order, the exchanges stopped requiring low-income applicants who estimated income  over 100% FPL to provide documentation if the government’s “trusted sources” of information indicated an  income below the threshold.

Comparatively weak enrollment growth in Wisconsin may support the hypothesis that under pressure of the pandemic, some enrollees in other non-expansion states are climbing out of the coverage gap. Alone among non-expansion states, Wisconsin has no coverage gap, as the state provides Medicaid to adults with incomes up to 100% FPL (rather than up to the 138% FPL threshold required by the ACA Medicaid expansion, which offers enhanced federal funding to participating states). In Wisconsin, those whose income falls below the 100% FPL marketplace eligibility threshold have access to free coverage. Wisconsin is the only non-expansion state that did not experience double-digit enrollment growth in OEP 2022 or from 2020-2022.

The American Rescue Plan was conceived as emergency pandemic relief, and its increased subsidies run only through 2022. President Biden’s Build Back Better bill, which passed in the House of Representatives but is currently stalled in the Senate, would extend the ARP subsidies through 2025 or possibly further.

The large increase in enrollment this year should add pressure on Congress to extend the improved subsidies into future years. Consumer response to the increased subsidies has proved immediate and dramatic. The ARP subsidy boosts brought the Affordable Care Act much closer than previously to living up to the promise of “affordable” care expressed in its name. Going backwards on that promise should not be seen as a politically viable or ethical path.

* * *

* Another million people are enrolled in Basic Health Programs established under the ACA by Minnesota and New York – low-cost, Medicaid-like programs for state residents with incomes under 200% FPL. Enrollment in these programs is on track to increase by 13% this year, according to Charles Gaba’s estimate.

** HealthCare.gov all-state totals are for the 33 states using the federal exchange this year. Source: Charles Gaba, OE snapshots as of mid-December, 2021-22, 2020-2021; see also CMS end-of-OEP snapshots for 2020, 2021, 2022

Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid. His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic, and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D. in English literature from the University of Rochester.

Just before Thanksgiving, the House of Representatives passed the Build Back Better Act (HR5376) and sent it to the Senate. The version that the House approved was scaled down from the initial proposal, but it’s still a robust bill that would create jobs, protect the environment, help families meet their needs, and improve access to health care.

Lawmakers had initially hoped that the bill would be enacted before Christmas. But the situation has changed in December, with West Virginia Senator Joe Manchin stating recently that he will not vote for the current Build Back Better legislation. The situation is still in flux, and it’s noteworthy that the nation’s largest coal miners union has asked Manchin to reconsider his position.

For the time being, we don’t know what might come of this. Manchin might reconsider, or the legislation might be changed to support his earlier requests, or it might be scrapped altogether and replaced with various piecemeal bills.

But for now, we wanted to explain how the House’s version of the Build Back Better Act would affect your health insurance in 2022 and future years. We’ll also clarify what you can already count on in 2022, even without the Build Back Better Act. And how should you handle the current open enrollment period, given that the legislation is still up in the air?

Let’s start with a summary of how the House’s version of the BBBA would affect people who buy their own health insurance (keeping in mind that we don’t know whether the Senate will pass any version of the BBBA, and if they do, what changes might be incorporated):

The enhanced premium tax credit (subsidy) structure created by the American Rescue Plan (ARP) would remain in place through 2025, instead of ending after 2022. This would mean:

• There would continue to be no “subsidy cliff” through 2025. Subsidies would be available to households earning more than 400% of the poverty level, as long as the cost of the benchmark plan would otherwise be more than 8.5% of household income.
• Subsidies would continue to be larger than they were prior to the ARP. People with household income up to 150% of the poverty level would be able to enroll in the benchmark plan at no cost. And people with income above that level would continue to pay a smaller percentage of their income for the benchmark plan, relative to what they had to pay pre-ARP.

These enhanced subsidies have made coverage much more affordable in 2021, and the BBBA would extend them for another three years.

It’s also important to note that HHS finalized a new rule this year that allows year-round enrollment via HealthCare.gov for people whose income doesn’t exceed 150% of the poverty level. This rule remains in place for as long as people at that income level are eligible for $0 premium benchmark plans. Under the ARP, that would just be through 2022. But the BBBA would extend the availability of this special enrollment opportunity through 2025.

The ARP’s subsidies related to unemployment compensation would be available in 2022, instead of ending after this year. The Congressional Budget Office (CBO) projects that about a million people will receive these enhanced subsidies, and that about half of them would otherwise be uninsured in 2022.

Under the ARP, if a person receives unemployment compensation at any point in 2021, any income above 133% of the poverty level is disregarded when they apply for a marketplace plan. That means they’re eligible for a $0 benchmark plan and full cost-sharing reductions (CSR).

The BBBA would set the income disregard threshold at 150% of FPL for a person who receives unemployment compensation in 2022. But the effect would be the same, as applicants at that income are eligible for $0 benchmark plans and full CSR. As noted above, there’s also a year-round enrollment opportunity for people whose income doesn’t exceed 150% of the poverty level (that’s available in all states that use HealthCare.gov; state-run marketplaces can choose whether or not to offer it).

As is the case under the ARP, the unemployment-related subsidies would be available for the whole year if the person receives unemployment compensation for at least one week of the year. But as is also the case under the ARP, the marketplace subsidies would not be available for any month that the person is eligible for Medicare or an employer-sponsored plan that’s considered affordable and provides minimum value.

In 11 states that have refused to expand Medicaid under the Affordable Care Act, there’s a coverage gap for people whose income is under the poverty level. As of 2019, there were more than 2.2 million people caught in this coverage gap (mostly in Texas, Florida, Georgia, and North Carolina). They are ineligible for Medicaid and also ineligible for premium subsidies in the marketplace.

The BBBA would close the coverage gap for 2022 through 2025. The current rules (which only allow marketplace premium subsidies if an applicant’s income is at least 100% of the poverty level) would be changed to allow premium subsidies regardless of how low a person’s income is.

This would be applicable nationwide, but subsidies would continue to be unavailable if a person is eligible for Medicaid. So in most states, subsidies would continue to be available only for applicants with income above 138% of the poverty level, as Medicaid is available below that level in the 38 states that have expanded Medicaid under the ACA.

In 2022, people who would otherwise be in the coverage gap would be eligible for $0 benchmark plans and full cost-sharing reductions (CSR). In 2023 through 2025, they would continue to be eligible for $0 benchmark plans, and their cost-sharing reductions would become more robust. Instead of covering 94% of costs for an average standard population (which is currently the most robust level of CSR), their plans would cover 99% of a standard population’s costs.

The CBO projects that the BBBA’s subsidy enhancements would increase the number of people with subsidized marketplace coverage by about 3.6 million. Many of those individuals would otherwise be in the coverage gap and uninsured.

Nothing would change about Medicaid eligibility or subsidy eligibility in the states that have expanded Medicaid. But the BBBA would provide additional federal funding for Medicaid expansion in those states for 2023 through 2025. Currently, the federal government pays 90% of the cost of Medicaid expansion, and that would grow to 93% for those three years.

This requirement would apply to catastrophic plans as well as metal-level plans. And although HSA-qualified high-deductible health plans are often excluded from new coverage mandates, that would not be the case here. In 2019, the IRS implemented new rules that allow HSA-qualified plans to cover, on a pre-deductible basis, some types of care aimed at controlling chronic conditions; insulin is among them.

Under ACA rules, a person cannot get premium subsidies in the marketplace if they have access to an employer-sponsored plan that provides minimum value and is considered affordable.

Under current rules, an employer-sponsored plan would be considered affordable in 2022 if the employee’s cost for employee-only coverage isn’t more than 9.61% of the employee’s household income. Under the BBBA, this threshold would be reset to 8.5% of household income for 2022 through 2025.

For some employees, this would make marketplace subsidies newly available. And for others, employers might opt to cover more of their premium costs, making their employer-sponsored coverage more affordable. But some employers might simply stop offering employer-sponsored coverage altogether, despite the fact that they would potentially be subject to the ACA’s employer mandate penalty if they have 50 or more employees (if an employer stops offering coverage, the employees can enroll in a marketplace plan with income-based subsidies).

It’s important to note that the BBBA would not address the family glitch. So the family members of employees who have an offer of affordable self-only coverage would continue to be ineligible for marketplace subsidies if they have access to the employer-sponsored plan, regardless of the cost. But prominent health law scholars have opined that the Biden administration could fix the family glitch administratively, without legislation. There is some cause to hope that the administration may do so.

The ACA has its own definition of modified adjusted gross income (MAGI), used to determine eligibility for premium tax credits and cost-sharing reductions (a very similar version of MAGI is used to determine eligibility for CHIP, Medicaid expansion, and Medicaid for children and pregnant women).

The BBBA would make a couple of changes to the way MAGI is calculated when a tax dependent has income or the household receives a lump sum payment from Social Security:

• Through 2026, the first $3,500 in income earned by dependents would not have to be added to the family’s household income.
• From 2022 onward, lump sum Social Security payments attributable to prior years would not have to be included in a person’s MAGI. The median processing time for a Social Security disability appeal is well over a year, so it’s common for people to wait a long time and then suddenly receive several months of Social Security payments all at one time. This can sometimes result in them having to repay premium tax credits for the year in which they receive the lump sum. The BBBA would prevent that in future years.

What does this mean for the current open enrollment period?

Given that the legislation is still up in the air, here’s what you need to keep in mind when enrolling in coverage for 2022:

General subsidies

• There is no set income cap for marketplace subsidies in 2022. That provision is already in place, and doesn’t depend on the BBBA. (Your eligibility for a subsidy does depend on your income, but that eligibility now extends above 400% of the poverty level in most places, depending on your age.)
• The more robust subsidy structure that the ARP introduced this year will continue to be in effect in 2022, regardless of whether the BBBA is enacted.
• Subsidies are much larger and more widely available than they were last fall. And most of the ARP’s subsidy enhancements were already slated to continue through 2022. This means most enrollees can sign up now and rest assured that their 2022 coverage options and subsidy amounts will not change if and when the BBBA is enacted.

Unemployment-related subsidies

• If you received unemployment compensation in 2021 and got the ARP’s unemployment-related subsidies, you may find that your after-subsidy premium is currently slated to increase significantly for 2022, due to the expiration of the unemployment-based subsidies.
• If you’re still going to be receiving unemployment compensation after the start of 2022, you might end up qualifying for another round of robust subsidies in 2022. But that will depend on the BBBA. For the time being, the application will just ask for your projected income, which will need to include the total amount that you expect to earn in 2022. That might result in a substantial subsidy or not, depending on your household’s specific details.
• The fact that open enrollment continues through at least January 15 in most states can be used to your advantage. For now, you can enroll in the plan that best fits your budget based on the existing subsidy rules for 2022. (In some states, you still have time to sign up for coverage that starts January 1, although most states are now enrolling people in plans with February effective dates.) If the BBBA is enacted in early January, you would then have a chance to pick a different plan prior to the end of the open enrollment period. It would have a February effective date (or March, depending on the state) and your out-of-pocket costs would reset to $0 on the new plan. But for some people, this will be the opportunity to upgrade from a Bronze plan to a Silver plan, so it’s worth considering as an option if you know that you’ll still be receiving unemployment compensation after the start of 2022.
• If the BBBA isn’t enacted by mid-January, you should still keep an eye on this. A different version of the bill, or smaller piecemeal versions, might be enacted later in 2022. If that happens and unemployment-based subsidies are included in the final legislation, you might become eligible for new subsidies at that point. That may or may not come with a special enrollment period to allow people receiving unemployment compensation to switch plans. For now, it’s all up in the air, but the situation could change in 2022.

Learn how you might avoid the coverage gap

If you have a low income, are in a state that hasn’t expanded Medicaid, and the marketplace is showing that you’re not eligible for any premium tax credits, you’ll want to read this article about ways to avoid the coverage gap.

Assuming you can’t get out of the coverage gap for the time being, you’ll want to keep a close eye on the BBBA. If it’s enacted with the same coverage gap provisions that the House approved, you may be eligible for full premium tax credits as of early 2022. And you’d have a chance to enroll in coverage at that point.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

Just before Thanksgiving, the House of Representatives passed the Build Back Better Act (HR5376) and sent it to the Senate. The version that the House approved was scaled down from the initial proposal, but it’s still a robust bill that would create jobs, protect the environment, help families meet their needs, and improve access to health care.

Lawmakers had initially hoped that the bill would be enacted before Christmas. But the situation has changed in December, with West Virginia Senator Joe Manchin stating recently that he will not vote for the current Build Back Better legislation. The situation is still in flux, and it’s noteworthy that the nation’s largest coal miners union has asked Manchin to reconsider his position.

For the time being, we don’t know what might come of this. Manchin might reconsider, or the legislation might be changed to support his earlier requests, or it might be scrapped altogether and replaced with various piecemeal bills.

But for now, we wanted to explain how the House’s version of the Build Back Better Act would affect your health insurance in 2022 and future years. We’ll also clarify what you can already count on in 2022, even without the Build Back Better Act. And how should you handle the current open enrollment period, given that the legislation is still up in the air?

Let’s start with a summary of how the House’s version of the BBBA would affect people who buy their own health insurance (keeping in mind that we don’t know whether the Senate will pass any version of the BBBA, and if they do, what changes might be incorporated):

The enhanced premium tax credit (subsidy) structure created by the American Rescue Plan (ARP) would remain in place through 2025, instead of ending after 2022. This would mean:

• There would continue to be no “subsidy cliff” through 2025. Subsidies would be available to households earning more than 400% of the poverty level, as long as the cost of the benchmark plan would otherwise be more than 8.5% of household income.
• Subsidies would continue to be larger than they were prior to the ARP. People with household income up to 150% of the poverty level would be able to enroll in the benchmark plan at no cost. And people with income above that level would continue to pay a smaller percentage of their income for the benchmark plan, relative to what they had to pay pre-ARP.

These enhanced subsidies have made coverage much more affordable in 2021, and the BBBA would extend them for another three years.

It’s also important to note that HHS finalized a new rule this year that allows year-round enrollment via HealthCare.gov for people whose income doesn’t exceed 150% of the poverty level. This rule remains in place for as long as people at that income level are eligible for $0 premium benchmark plans. Under the ARP, that would just be through 2022. But the BBBA would extend the availability of this special enrollment opportunity through 2025.

The ARP’s subsidies related to unemployment compensation would be available in 2022, instead of ending after this year. The Congressional Budget Office (CBO) projects that about a million people will receive these enhanced subsidies, and that about half of them would otherwise be uninsured in 2022.

Under the ARP, if a person receives unemployment compensation at any point in 2021, any income above 133% of the poverty level is disregarded when they apply for a marketplace plan. That means they’re eligible for a $0 benchmark plan and full cost-sharing reductions (CSR).

The BBBA would set the income disregard threshold at 150% of FPL for a person who receives unemployment compensation in 2022. But the effect would be the same, as applicants at that income are eligible for $0 benchmark plans and full CSR. As noted above, there’s also a year-round enrollment opportunity for people whose income doesn’t exceed 150% of the poverty level (that’s available in all states that use HealthCare.gov; state-run marketplaces can choose whether or not to offer it).

As is the case under the ARP, the unemployment-related subsidies would be available for the whole year if the person receives unemployment compensation for at least one week of the year. But as is also the case under the ARP, the marketplace subsidies would not be available for any month that the person is eligible for Medicare or an employer-sponsored plan that’s considered affordable and provides minimum value.

In 11 states that have refused to expand Medicaid under the Affordable Care Act, there’s a coverage gap for people whose income is under the poverty level. As of 2019, there were more than 2.2 million people caught in this coverage gap (mostly in Texas, Florida, Georgia, and North Carolina). They are ineligible for Medicaid and also ineligible for premium subsidies in the marketplace.

The BBBA would close the coverage gap for 2022 through 2025. The current rules (which only allow marketplace premium subsidies if an applicant’s income is at least 100% of the poverty level) would be changed to allow premium subsidies regardless of how low a person’s income is.

This would be applicable nationwide, but subsidies would continue to be unavailable if a person is eligible for Medicaid. So in most states, subsidies would continue to be available only for applicants with income above 138% of the poverty level, as Medicaid is available below that level in the 38 states that have expanded Medicaid under the ACA.

In 2022, people who would otherwise be in the coverage gap would be eligible for $0 benchmark plans and full cost-sharing reductions (CSR). In 2023 through 2025, they would continue to be eligible for $0 benchmark plans, and their cost-sharing reductions would become more robust. Instead of covering 94% of costs for an average standard population (which is currently the most robust level of CSR), their plans would cover 99% of a standard population’s costs.

The CBO projects that the BBBA’s subsidy enhancements would increase the number of people with subsidized marketplace coverage by about 3.6 million. Many of those individuals would otherwise be in the coverage gap and uninsured.

Nothing would change about Medicaid eligibility or subsidy eligibility in the states that have expanded Medicaid. But the BBBA would provide additional federal funding for Medicaid expansion in those states for 2023 through 2025. Currently, the federal government pays 90% of the cost of Medicaid expansion, and that would grow to 93% for those three years.

This requirement would apply to catastrophic plans as well as metal-level plans. And although HSA-qualified high-deductible health plans are often excluded from new coverage mandates, that would not be the case here. In 2019, the IRS implemented new rules that allow HSA-qualified plans to cover, on a pre-deductible basis, some types of care aimed at controlling chronic conditions; insulin is among them.

Under ACA rules, a person cannot get premium subsidies in the marketplace if they have access to an employer-sponsored plan that provides minimum value and is considered affordable.

Under current rules, an employer-sponsored plan would be considered affordable in 2022 if the employee’s cost for employee-only coverage isn’t more than 9.61% of the employee’s household income. Under the BBBA, this threshold would be reset to 8.5% of household income for 2022 through 2025.

For some employees, this would make marketplace subsidies newly available. And for others, employers might opt to cover more of their premium costs, making their employer-sponsored coverage more affordable. But some employers might simply stop offering employer-sponsored coverage altogether, despite the fact that they would potentially be subject to the ACA’s employer mandate penalty if they have 50 or more employees (if an employer stops offering coverage, the employees can enroll in a marketplace plan with income-based subsidies).

It’s important to note that the BBBA would not address the family glitch. So the family members of employees who have an offer of affordable self-only coverage would continue to be ineligible for marketplace subsidies if they have access to the employer-sponsored plan, regardless of the cost. But prominent health law scholars have opined that the Biden administration could fix the family glitch administratively, without legislation. There is some cause to hope that the administration may do so.

The ACA has its own definition of modified adjusted gross income (MAGI), used to determine eligibility for premium tax credits and cost-sharing reductions (a very similar version of MAGI is used to determine eligibility for CHIP, Medicaid expansion, and Medicaid for children and pregnant women).

The BBBA would make a couple of changes to the way MAGI is calculated when a tax dependent has income or the household receives a lump sum payment from Social Security:

• Through 2026, the first $3,500 in income earned by dependents would not have to be added to the family’s household income.
• From 2022 onward, lump sum Social Security payments attributable to prior years would not have to be included in a person’s MAGI. The median processing time for a Social Security disability appeal is well over a year, so it’s common for people to wait a long time and then suddenly receive several months of Social Security payments all at one time. This can sometimes result in them having to repay premium tax credits for the year in which they receive the lump sum. The BBBA would prevent that in future years.

What does this mean for the current open enrollment period?

Given that the legislation is still up in the air, here’s what you need to keep in mind when enrolling in coverage for 2022:

General subsidies

• There is no set income cap for marketplace subsidies in 2022. That provision is already in place, and doesn’t depend on the BBBA. (Your eligibility for a subsidy does depend on your income, but that eligibility now extends above 400% of the poverty level in most places, depending on your age.)
• The more robust subsidy structure that the ARP introduced this year will continue to be in effect in 2022, regardless of whether the BBBA is enacted.
• Subsidies are much larger and more widely available than they were last fall. And most of the ARP’s subsidy enhancements were already slated to continue through 2022. This means most enrollees can sign up now and rest assured that their 2022 coverage options and subsidy amounts will not change if and when the BBBA is enacted.

Unemployment-related subsidies

• If you received unemployment compensation in 2021 and got the ARP’s unemployment-related subsidies, you may find that your after-subsidy premium is currently slated to increase significantly for 2022, due to the expiration of the unemployment-based subsidies.
• If you’re still going to be receiving unemployment compensation after the start of 2022, you might end up qualifying for another round of robust subsidies in 2022. But that will depend on the BBBA. For the time being, the application will just ask for your projected income, which will need to include the total amount that you expect to earn in 2022. That might result in a substantial subsidy or not, depending on your household’s specific details.
• The fact that open enrollment continues through at least January 15 in most states can be used to your advantage. For now, you can enroll in the plan that best fits your budget based on the existing subsidy rules for 2022. (In some states, you still have time to sign up for coverage that starts January 1, although most states are now enrolling people in plans with February effective dates.) If the BBBA is enacted in early January, you would then have a chance to pick a different plan prior to the end of the open enrollment period. It would have a February effective date (or March, depending on the state) and your out-of-pocket costs would reset to $0 on the new plan. But for some people, this will be the opportunity to upgrade from a Bronze plan to a Silver plan, so it’s worth considering as an option if you know that you’ll still be receiving unemployment compensation after the start of 2022.
• If the BBBA isn’t enacted by mid-January, you should still keep an eye on this. A different version of the bill, or smaller piecemeal versions, might be enacted later in 2022. If that happens and unemployment-based subsidies are included in the final legislation, you might become eligible for new subsidies at that point. That may or may not come with a special enrollment period to allow people receiving unemployment compensation to switch plans. For now, it’s all up in the air, but the situation could change in 2022.

Learn how you might avoid the coverage gap

If you have a low income, are in a state that hasn’t expanded Medicaid, and the marketplace is showing that you’re not eligible for any premium tax credits, you’ll want to read this article about ways to avoid the coverage gap.

Assuming you can’t get out of the coverage gap for the time being, you’ll want to keep a close eye on the BBBA. If it’s enacted with the same coverage gap provisions that the House approved, you may be eligible for full premium tax credits as of early 2022. And you’d have a chance to enroll in coverage at that point.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

As has been the case for the last few years, average individual and family health insurance rate changes for 2022 are mostly modest. The nationwide average increase is about 3.5%, and there are new insurers joining the marketplaces in the majority of the states.

That all sounds like great news, but the reality is a bit more complex. The modest average rate changes apply to full-price plans, but most marketplace enrollees do not pay full price. And although new insurers bring added competition, their entry could also mean a sharp reduction in premium subsidy amounts, depending on how the new insurer prices its plans.

So despite the headlines about small average rate changes, the rate change for your specific plan might be nowhere near that average. But that doesn’t necessarily mean you have to swallow a large increase.

The annual premium changes that grab headlines and that factor into state and federal averages are for full-price premiums. But very few marketplace/exchange enrollees pay full price. Most receive premium tax credits (subsidies), which means that their rate changes will also depend on how much their subsidy amount fluctuates from one year to the next.

ACA tax credits are set so that the enrollee pays a fixed percentage of income for the benchmark plan – the second-cheapest Silver plan in their area. When the unsubsidized benchmark plan premium changes from year-to-year, so does the size of the tax credit. If a discount insurer enters the market, your tax credit may shrink. That doesn’t matter if you choose the benchmark plan, but it may make other plans more expensive.

The averages also lump each insurer’s plans together, so although an insurer might have an average rate change of 5%, it could have a range of -10% to +20% across all of its plans.

And average rate changes also don’t account for the fact that rates increase with age. Even if your health plan has no annual rate changes at all for any of its plans, your pre-subsidy price will still be higher in the coming year simply because you’re a year older (if you receive subsidies, the subsidies will increase to keep pace with the age-related premium increases).

Let’s consider Monique, who is 36 years old, lives in Lincoln, Nebraska, and has an annual income of $35,000. This year, she’s enrolled in a Silver EPO plan from Medica (Medica with CHI Health Silver Copay) that has a $4,800 deductible, $45 copays for primary care visits, and an $8,150 cap on out-of-pocket costs. She pays no monthly premiums at all, because the full-price cost of the plan in 2021 is $504/month (based on her being 35 when she enrolled in that plan), and she’s eligible for a subsidy of $513/month.

Full-price premiums in Nebraska are increasing by more than the national average for 2022, with an average increase of a little less than 9%. But imagine Monique’s surprise when her renewal notice showed that her after-subsidy premium would be going from $0/month in 2021 to $226/month in 2022.

Why is her premium going up so much, when average full-price rate increases in Nebraska are in the single-digit range?

Nebraska is a good example of a place where there’s a lot more competition in 2022. Oscar and Ambetter have both joined the marketplace statewide, and the number of available plans has more than quadrupled. When Monique was shopping for plans last fall, she had a total of 22 options from which to choose. For 2022, however, she can pick from among 95 different plans.

In 2021, the benchmark plan (second-lowest-cost Silver plan) was offered by Medica and had a pre-subsidy price tag of $657/month. But for 2022, Ambetter offers the lowest-cost Silver plans in Lincoln, so they have taken over the benchmark spot. And the second-lowest-cost Silver plan for a 36-year-old now has a pre-subsidy premium of just $475.

So in Monique’s case, the cost of the benchmark plan has dropped by $182/month. And since subsidy amounts are based on the cost of the benchmark plan, Monique’s subsidy is also much smaller for 2022 – it doesn’t need to be as large in order to keep the cost of the benchmark plan at the level that’s considered affordable.

In addition, Medica has raised the base price of Monique’s plan from $504/month in 2021 to $560/month in 2022. That’s partially due to Monique’s increasing age, and partially due to the 10% overall average rate increase that Medica imposed for 2022.

The two plans at that price both have lower out-of-pocket costs than her current plan. (They’re capped at $6,450 and $6,100, versus $8,550, which is the new out-of-pocket limit that her existing plan will have in 2022.) But non-preventive office visits are only covered after the deductible is met, whereas her current plan has copays for office visits right from the start. (Certain preventive care is covered in full on all plans, without a need to pay any deductible or copays.)

The fact that there are more plans available in most areas of the country for 2022 can be a plus or a minus, depending on the circumstances. In Monique’s case, a new plan has taken over the benchmark spot and reduced her subsidy amount. But there are also dozens of other new plans in her area, many of which might be a perfect fit for her medical needs.

In order to pick a plan, Monique will need to consider the whole picture, including total premium costs, expected out-of-pocket medical costs, and provider networks. If she takes any medications, she’ll need to compare the various plan options to see whether her drugs are covered and how much she can expect to pay at the pharmacy.

Although this article focuses on plans available in Lincoln, Nebraska, people in other parts of the country can be facing varying degrees of surprising net rate increases, even when overall full-price rate changes in their area are fairly modest.

In states that use HealthCare.gov, the average enrollee can select from among almost 108 plans for 2022, up from just 61 in 2021. Even if the benchmark plan in your area has remained unchanged, the influx of new plans might mean that there’s a better option available for you in 2022, and now’s your chance to switch your coverage. It’s never in your best interest to just let your plan auto-renew without considering the other options, and that’s especially true when there are so many new plans available.

In every community, there are brokers and Navigators who can help you understand what’s happening with your current plan, and consider whether a plan change might be in your best interest. For more information about selecting a plan during open – and open enrollment deadlines in your state – read our 2022 Guide to ACA Open Enrollment.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

As has been the case for the last few years, average individual and family health insurance rate changes for 2022 are mostly modest. The nationwide average increase is about 3.5%, and there are new insurers joining the marketplaces in the majority of the states.

That all sounds like great news, but the reality is a bit more complex. The modest average rate changes apply to full-price plans, but most marketplace enrollees do not pay full price. And although new insurers bring added competition, their entry could also mean a sharp reduction in premium subsidy amounts, depending on how the new insurer prices its plans.

So despite the headlines about small average rate changes, the rate change for your specific plan might be nowhere near that average. But that doesn’t necessarily mean you have to swallow a large increase.

The annual premium changes that grab headlines and that factor into state and federal averages are for full-price premiums. But very few marketplace/exchange enrollees pay full price. Most receive premium tax credits (subsidies), which means that their rate changes will also depend on how much their subsidy amount fluctuates from one year to the next.

ACA tax credits are set so that the enrollee pays a fixed percentage of income for the benchmark plan – the second-cheapest Silver plan in their area. When the unsubsidized benchmark plan premium changes from year-to-year, so does the size of the tax credit. If a discount insurer enters the market, your tax credit may shrink. That doesn’t matter if you choose the benchmark plan, but it may make other plans more expensive.

The averages also lump each insurer’s plans together, so although an insurer might have an average rate change of 5%, it could have a range of -10% to +20% across all of its plans.

And average rate changes also don’t account for the fact that rates increase with age. Even if your health plan has no annual rate changes at all for any of its plans, your pre-subsidy price will still be higher in the coming year simply because you’re a year older (if you receive subsidies, the subsidies will increase to keep pace with the age-related premium increases).

Let’s consider Monique, who is 36 years old, lives in Lincoln, Nebraska, and has an annual income of $35,000. This year, she’s enrolled in a Silver EPO plan from Medica (Medica with CHI Health Silver Copay) that has a $4,800 deductible, $45 copays for primary care visits, and an $8,150 cap on out-of-pocket costs. She pays no monthly premiums at all, because the full-price cost of the plan in 2021 is $504/month (based on her being 35 when she enrolled in that plan), and she’s eligible for a subsidy of $513/month.

Full-price premiums in Nebraska are increasing by more than the national average for 2022, with an average increase of a little less than 9%. But imagine Monique’s surprise when her renewal notice showed that her after-subsidy premium would be going from $0/month in 2021 to $226/month in 2022.

Why is her premium going up so much, when average full-price rate increases in Nebraska are in the single-digit range?

Nebraska is a good example of a place where there’s a lot more competition in 2022. Oscar and Ambetter have both joined the marketplace statewide, and the number of available plans has more than quadrupled. When Monique was shopping for plans last fall, she had a total of 22 options from which to choose. For 2022, however, she can pick from among 95 different plans.

In 2021, the benchmark plan (second-lowest-cost Silver plan) was offered by Medica and had a pre-subsidy price tag of $657/month. But for 2022, Ambetter offers the lowest-cost Silver plans in Lincoln, so they have taken over the benchmark spot. And the second-lowest-cost Silver plan for a 36-year-old now has a pre-subsidy premium of just $475.

So in Monique’s case, the cost of the benchmark plan has dropped by $182/month. And since subsidy amounts are based on the cost of the benchmark plan, Monique’s subsidy is also much smaller for 2022 – it doesn’t need to be as large in order to keep the cost of the benchmark plan at the level that’s considered affordable.

In addition, Medica has raised the base price of Monique’s plan from $504/month in 2021 to $560/month in 2022. That’s partially due to Monique’s increasing age, and partially due to the 10% overall average rate increase that Medica imposed for 2022.

The two plans at that price both have lower out-of-pocket costs than her current plan. (They’re capped at $6,450 and $6,100, versus $8,550, which is the new out-of-pocket limit that her existing plan will have in 2022.) But non-preventive office visits are only covered after the deductible is met, whereas her current plan has copays for office visits right from the start. (Certain preventive care is covered in full on all plans, without a need to pay any deductible or copays.)

The fact that there are more plans available in most areas of the country for 2022 can be a plus or a minus, depending on the circumstances. In Monique’s case, a new plan has taken over the benchmark spot and reduced her subsidy amount. But there are also dozens of other new plans in her area, many of which might be a perfect fit for her medical needs.

In order to pick a plan, Monique will need to consider the whole picture, including total premium costs, expected out-of-pocket medical costs, and provider networks. If she takes any medications, she’ll need to compare the various plan options to see whether her drugs are covered and how much she can expect to pay at the pharmacy.

Although this article focuses on plans available in Lincoln, Nebraska, people in other parts of the country can be facing varying degrees of surprising net rate increases, even when overall full-price rate changes in their area are fairly modest.

In states that use HealthCare.gov, the average enrollee can select from among almost 108 plans for 2022, up from just 61 in 2021. Even if the benchmark plan in your area has remained unchanged, the influx of new plans might mean that there’s a better option available for you in 2022, and now’s your chance to switch your coverage. It’s never in your best interest to just let your plan auto-renew without considering the other options, and that’s especially true when there are so many new plans available.

In every community, there are brokers and Navigators who can help you understand what’s happening with your current plan, and consider whether a plan change might be in your best interest. For more information about selecting a plan during open – and open enrollment deadlines in your state – read our 2022 Guide to ACA Open Enrollment.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

Open enrollment for 2022 person/spouse and children health coverage commenced on November 1. The enrollment window is more time this yr, continuing until at the very least January 15 in virtually each state. (For now, Idaho nonetheless plans to end the open up enrollment time period on December 15.)

The for a longer time open up enrollment period of time does give men and women some extra wiggle home in the course of the hectic holiday break year. But for most people today, December 15 is still the tender deadline you’re likely to want to retain in head. In most states, which is the past working day you can enroll in protection that will take impact January 1.

But in the relaxation of the region, you have to have to enroll by December 15 to have your approach start off on January 1. And which is vital for a number of reasons.

If you’re not previously enrolled in ACA-compliant coverage in 2021, the latest open up enrollment period of time is your chance to change that for 2022.

But if you wait right up until the very last moment to enroll, you won’t have protection in position when the new calendar year commences. As a substitute, you are going to be ready right until February 1 — or March 1 – if you enroll at the final minute in a couple of states with for a longer period enrollment home windows.

If you regarded market protection in the past and uncovered it to be unaffordable, you might presently be uninsured or enrolled in a prepare that is not controlled by the ACA. Or you could have opted to acquire ACA-compliant coverage outside the house the exchange, if you weren’t qualified for premium tax credits (subsidies) the previous time you appeared.

But many thanks to the American Rescue Prepare, a lot of men and women who weren’t suitable for subsidies in previous a long time will uncover that they are now. All those subsidies are only obtainable if you are enrolled in a marketplace/trade plan, and the recent open enrollment period is your chance to make the switch to a market system.

In addition to becoming extra greatly out there, top quality subsidies are also more substantial than they were being previous tumble. Folks who didn’t enroll final 12 months thanks to the charge may possibly find that protection now suits in their price range.

Four out of five individuals browsing for coverage in the 33 states that use the federally-run market (Health care.gov) will obtain that they can get coverage for $10/month or considerably less. And tens of millions of uninsured People in america are suitable for top quality-totally free coverage in the marketplace, but may well not notice this.

Ready until the previous moment to enroll in protection will indicate that you leave all that income on the desk for January. You can use our subsidy calculator to get an idea of how a lot your subsidy will be for 2022. Then, make certain you enroll by December 15 so that you’re qualified to declare the subsidy for all 12 months of the year.

If you already have protection via the market in 2021 and are planning to just permit it vehicle-renew for 2021, you may wake up on January 1 with coverage and a quality that are not what you predicted.

Even if you’re 100% joyful with the plan you have now, you owe it to you to commit at minimum a small time examining out the obtainable solutions in advance of December 15. The quality that your insurance provider fees is probable modifying for 2022. And your subsidy quantity could possibly also be transforming, in particular if there are new insurers joining the marketplace in your place.

Your insurance company may also be making modifications to your positive aspects, company community, or lined drug listing — or even discontinuing the system completely and changing it with a new 1. In limited, the prepare and rate you have on January 1 may well be really distinct from what you have now.

This is portion of the purpose HHS opted to lengthen the open enrollment period – in purchase to give men and women a opportunity for a “do-over” if their vehicle-renewed strategy isn’t what they predicted. In just about every point out, you are going to have till at least January 15 to choose a new approach. But that strategy variety won’t be retroactive to January 1.

Louise Norris is an personal health insurance policy broker who has been producing about wellbeing insurance and health reform given that 2006. She has prepared dozens of opinions and academic items about the Very affordable Care Act for healthinsurance.org. Her state overall health exchange updates are regularly cited by media who deal with wellness reform and by other wellness insurance policy experts.

For hundreds of thousands of People in america, the open enrollment period of time (OEP) to store for 2022 ACA-compliant protection will be in contrast to any of the earlier eight OEPs. The cause? These consumers will – for the 1st time – be able to tap into the Reasonably priced Care Act’s top quality tax credits (far more generally referred to as wellness insurance policy subsidies).

Thanks to the American Rescue Prepare, consumers who in former several years could have observed themselves outdoors the qualified degree for subsidies – or who could have identified that subsidy amounts were being so reduced as to not be engaging – are now amongst all those suitable for quality tax credits. So if you haven’t shopped for overall health insurance plan lately, you may well be amazed to see how affordable your health and fitness protection selections are this slide (starting off November 1), and how quite a few prepare alternatives are available in your place.

Most persons who at the moment have coverage as a result of the wellness coverage exchanges have observed enhanced affordability this calendar year thanks to the American Rescue Prepare (ARP). That involves thousands and thousands of people today who had been already enrolled in programs when the ARP was enacted final March, as effectively as tens of millions of other people who signed up for the duration of the special enrollment time period that continued as a result of mid-August in most states (and is nevertheless ongoing in some states).

Use our up to date subsidy calculator to estimate how a lot you can help you save on your 2021 health and fitness insurance policy rates.

But there are continue to hundreds of thousands of other people who are possibly uninsured or have acquired protection somewhere else. And there are also people who presently had coverage in the exchange in 2021 but didn’t just take the choice to switch to a additional robust strategy right after the ARP was executed. If you’re in either of these types, you do not want to pass up the open up enrollment time period in the drop of 2021.

The Create Again Far better Act, which is however under thought in Congress, would prolong the ARP’s subsidies and ensure that well being insurance plan stays inexpensive in 2023 and further than. But even without any new legislative motion, most of the ARP’s subsidy enhancements will keep on being in area for 2022.

That indicates there will keep on to be no upper income restrict for high quality tax credit rating (subsidy) eligibility, and the proportion of income that individuals have to shell out for the benchmark system will carry on to be lower than it was in prior many years. The general end result is that subsidies are bigger than they were being in the earlier, and obtainable to a lot more persons.

Who ought to make a level to evaluation their subsidy eligibility?

So who requires to pay shut consideration this slide, in the course of open enrollment? In reality, everyone who does not have entry to Medicare, Medicaid, or an employer-sponsored well being plan – due to the fact even if you’re currently enrolled and delighted with the program you have, automobile-renewal is not in your greatest fascination.

But there are many groups of folks who seriously need to store for coverage this tumble. Let us just take a search at what each of these groups can assume, and why you shouldn’t enable open enrollment go you by if you’re in one particular of these categories:

The bulk of uninsured Americans cite the value of protection as the cause they do not have wellness insurance policy. Still hundreds of thousands of all those people are qualified for totally free or very very low-value health and fitness protection but have not still enrolled. This has been the scenario in prior several years as effectively, but high quality-free or pretty very low-price tag wellness programs are even more extensively readily available as a outcome of the ARP.

If you are uninsured due to the fact you never imagine well being insurance is very affordable, know that far more than a third of the people today who enrolled by means of Health care.gov all through the COVID/ARP special enrollment time period this calendar year purchased options for considerably less than $10/month.

Even if you have checked in former yrs and could not afford to pay for the programs that have been accessible, you’ll want to look at once more this slide, since the subsidy principles have modified given that final year.

There are hundreds of thousands of Individuals who have ordered wellbeing protection that is not compliant with the ACA. Most of these options are both considerably less robust than ACA-compliant plans, or use medical underwriting, or both. They contain:

Men and women invest in or continue to keep these ideas for a variety of factors. But chief amid them has long been the simple fact that ACA-compliant coverage was unaffordable – or was assumed to be unaffordable.

There are also individuals who favor some of the gains that some of these options give (the fellowship of becoming aspect of a health care sharing ministry, for occasion, or the abundantly obtainable principal treatment with a DPC membership). But by and substantial, the motive folks choose protection that isn’t ACA-compliant, or that is not even insurance coverage at all, is mainly because ACA-compliant coverage doesn’t in shape in their budgets.

This has lengthy bundled a number of main groups of folks: Those who attained too significantly to qualify for subsidies, these affected by the “spouse and children glitch,” and these who skilled for only nominal subsidy assistance and nevertheless felt that the coverage available in the trade wasn’t reasonably priced.

(A further group of people not able to manage protection are individuals who receive considerably less than the poverty level in 11 states that have refused to develop Medicaid and as a result have a coverage gap. Some people in the coverage gap order non-ACA-compliant protection, but this population is also probably to not have any coverage at all. If you or a liked 1 are in the protection gap, we really encourage you to examine this posting.)

The ARP has not fixed the family glitch or the protection gap, whilst there are legislative and administrative options less than consideration for every of these.

But the ARP has addressed the other two issues, and all those provisions keep on being in area for 2022. The profits cap for subsidy eligibility has been eliminated, which implies that some candidates can qualify for subsidies with profits considerably earlier mentioned 400% of the poverty level. And for those who were by now suitable for subsidies, the subsidy quantities are larger sized than they employed to be, generating protection far more very affordable.

So if you are enrolled in any form of self-acquired wellness approach that is not compliant with the ACA, you owe it to oneself to look at your on-trade selections this tumble, in the course of the open up enrollment period. Continue to keep in brain that you can do that via the trade, via an improved immediate enrollment entity, or with the support of a health coverage broker.

There are also persons who have “off-exchange” ACA-compliant strategies that they’ve acquired immediately from an insurance coverage firm, devoid of applying the exchange. (Notice that this is not the similar thing as enrolling in an on-trade ideas as a result of an enhanced immediate enrollment entity, lots of of which are insurance businesses).

There are a assortment of explanations people have decided on to enroll in off-trade well being programs about the very last several a long time. And for some of these enrollees, 2022 may well be the 12 months to swap to an on-trade system.

Considering that 2018, some persons have opted for off-exchange ideas if they weren’t eligible for high quality subsidies and needed to enroll in a Silver-degree approach. This was a incredibly rational option, encouraged by point out insurance policy commissioners and marketplaces alike. But if you’ve been acquiring off-trade protection in purchase to get a Silver prepare with a lower price tag, the main issue to retain in mind for 2022 is that you may find that you’re now qualified for top quality subsidies.

Just like the individuals described previously mentioned, who have enrolled in various non-ACA-compliant ideas in an energy to attain cost-effective coverage, the elimination of the money restrict for subsidy eligibility is a recreation changer for men and women who ended up buying off-exchange coverage to get a reduce cost on a Silver strategy.

Some folks have opted for off-trade coverage due to the fact their preferred overall health insurance company wasn’t collaborating in the trade in their space. This might have been a selecting factor for an applicant who was only suitable for a extremely smaller subsidy — or no subsidy at all — and was willing to pay full value for an off-exchange plan from the insurance provider of their alternative.

But 2022 is the fourth year in a row with increasing insurance company participation in the exchanges, and some large-identify insurers are joining or rejoining the exchanges in very a couple states. So if you haven’t checked your on-exchange solutions in a when, this drop is definitely the time to do so. You may well be amazed to see how a lot of options you have, and again, how affordable they are.

If you are now enrolled in an on-exchange system and you had given the trade a projection of your money for 2021, you likely observed your subsidy quantity maximize at some issue this calendar year.

But if the exchange didn’t have an revenue on file for you, they would not have been equipped to activate a subsidy on your behalf (on the Health care.gov platform, subsidy quantities were being routinely updated in September for persons who hadn’t updated their accounts by that place, but only if you had furnished a projected profits to the trade when you enrolled in coverage for 2021). And even if your subsidy total did get current, you may well have remained on the strategy you experienced picked final drop, irrespective of the possibility to select a distinct one particular just after the ARP was enacted.

The excellent information is that you are going to be capable to claim your complete top quality tax credit rating, for the entirety of 2021, when you file your 2021 tax return (assuming you had on-exchange overall health coverage throughout the year). And through the open enrollment period for 2022 protection, you can provide earnings details to the exchange so that a subsidy is paid on your behalf just about every month following year.

Reconsidering your approach choice throughout open enrollment could end up becoming useful as perfectly. If you didn’t qualify for a subsidy in the past, or if you only qualified for a modest subsidy, you could possibly have picked a Bronze program or even a catastrophic approach, in an exertion to retain your month-to-month premiums cost-effective.

But with the ARP in position, you might come across that you can afford to pay for a more sturdy well being strategy. And if your income doesn’t exceed 250% of the poverty level (and especially if it does not exceed 200% of the poverty degree), pay close notice to the obtainable Silver options. The larger subsidies may possibly make it attainable for you to afford to pay for a Silver approach with built-in charge-sharing reductions that considerably lower out-of-pocket prices.

One other stage to preserve in thoughts: If you are acquiring a quality subsidy this 12 months, be aware that it may possibly modify subsequent year owing to a new insurer coming into the market place in your spot and supplying reduce-priced programs. Here’s much more about how this performs, and what to take into consideration as you are shopping for coverage this fall.

The takeaway point below? Even if you’ve been delighted with your strategy, you need to check out your choices for the duration of open up enrollment. This is not the calendar year to let your system auto-renew. Be confident you’ve furnished the exchange with an updated profits projection for 2022, and actively evaluate the plans that are accessible to you. It is attainable that a program with far better protection or a broader provider community could be economical to you for 2022, even if it was financially out of reach when you checked final drop.

Louise Norris is an unique health and fitness insurance plan broker who has been crafting about well being coverage and wellbeing reform because 2006. She has published dozens of views and educational parts about the Cost-effective Care Act for healthinsurance.org. Her point out well being trade updates are regularly cited by media who go over health reform and by other wellness insurance plan specialists.

The American Rescue Plan, signed into law by President Biden on March 11 of this year, included major boosts to the affordability of health plans sold in the ACA marketplace for people of all incomes.

Effective through 2022 and likely to be made permanent by pending legislation, the ARP improvements to affordability were as follows:

• A benchmark Silver plan (the second least expensive Silver plan) with strong cost sharing reduction (CSR) subsidies became free to enrollees with household income up to 150% of the Federal Poverty Level (FPL) and costs no more than 2% of income for enrollees with income up to 200% FPL. That’s a maximum of $43 per month for a single person with an income of $25,520.
• The previous income cap on subsidy eligibility was removed, so that no one who lacks access to affordable coverage elsewhere (i.e., from an employer) has to pay more than 8.5% of income for a benchmark Silver plan (less at lower incomes). The eliminated cap was 400% FPL ($51,040 for an individual, $104,880 for a family of four), and some households with income well above that level now qualify for subsidies.
• The percentage of income required to buy a benchmark Silver plan was reduced at all income levels.
• Anyone who received any unemployment insurance income during 2021 was eligible for free high-CSR Silver coverage. (Note that the pending legislation calls for this subsidy enhancement to be extended by several years, but not necessarily made permanent.)

Our 2022 Open Enrollment Guide: Everything you need to know to enroll in an affordable individual-market health plan.

Preceding and then coinciding with these major subsidy boosts, the Biden administration had opened an emergency Special Enrollment Period (SEP) running from February 15 through August 15 in the 36 states that use the federal ACA exchange, HealthCare.gov.

The SEP, implemented to help Americans get covered during the pandemic, functioned like a second open enrollment period: anyone who lacked access to affordable coverage from other sources (e.g., employers) could enroll in a marketplace plan. The 15 state-based exchanges also opened emergency SEPs, with somewhat different durations and conditions, summarized here.

ARP prompted an enrollment surge during the 2021 SEP

The enhanced subsidies were posted on HealthCare.gov on April 1, and in the state-run exchanges within a few weeks of that date. Existing enrollees were encouraged to update their information and get the new subsidies credited, and were allowed to switch plans if they chose.

Americans responded with a major surge in new enrollment and enrollment upgrades. From February 15 through August 15:

• More than 2.8 million people enrolled in new health coverage. Of new enrollees, 91% qualified for premium subsidies.
• Of new enrollees, 44% obtained coverage for less than $10 per month. Most of these enrollees (41% in HealthCare.gov states) received free coverage with the highest level of CSR. As a result, the median deductible fell from $750 in 2020 to $50 this year – meaning that half of enrollees obtained a plan with a deductible at or below that level (most of them in high-CSR Silver plans).
• The average premium paid by new consumers during the SEP (Feb. 15 – Aug. 15) fell 30%, from $117 in 2020 to $81 in 2021.
• Marketplace enrollment in August 2021, at 12.2 million, was 15% higher than in August 2020, the previous August high, and 22% above the pre-pandemic August high (see p. 14 here) recorded in 2016.
• More than 200,000 new and existing enrollees qualified for free high-CSR Silver plans because they had received unemployment insurance income in 2021.

Savings were also dramatic for existing marketplace enrollees:

• 8 million existing enrollees reduced the premiums on their existing plans or obtained new plans after ARP implementation.
• Existing enrollees reduced their premiums by 50%, or by $67 per month, on average.

My premium went down how much?

To get a sense of the extent to which the ARP reduced enrollee costs (or encouraged people who might previously have considered coverage too expensive to enroll), consider these examples:

• In November 2020, a 40-year-old in Miami with an income of $24,000 per year would have paid $115 per month for the least expensive available Silver plan, with a $1,500 deductible, and $119 per month for the second-cheapest Silver plan, with a $0 deductible. Thanks to the ARP, those plans would now cost this person $26 and $30 per month, respectively.
• In November 2020, a pair of 60-year-olds in Dallas, Texas with an income of $70,000 – slightly over the income cap for premium subsidies, which the ARP eliminated – would have had to pay $1,669 per month for the lowest cost Gold plan, with a $2,300 deductible (Gold plans are cheaper than Silver Plans in Dallas), or $1,228 for the lowest cost Bronze plan, with an $8,550 deductible.
  Now, this couple can choose to pay $393 per month for the Gold plan (which includes free doctor visits and generic drug prescriptions, neither subject to the deductible), or consider two free Bronze plans with deductibles over $8,000, a $2/month Bronze plan with a $6,100 deductible, and other options. A BlueCross Silver plan available for $420 per month might also be in the mix, if, say, the provider network is preferable.

Which states saw the biggest gains in new enrollees?

The new enrollment surge – and the savings – was particularly strong in twelve states that had not enacted the ACA Medicaid expansion as of June 2021. Due to their failure to expand Medicaid, these states have a “coverage gap” for people who earn too little to qualify for marketplace coverage (less than 100% FPL, or $12,760 for an individual in 2021) but mostly also don’t qualify for Medicaid because of their states’ restrictive Medicaid eligibility. (That excludes Wisconsin, which has not enacted the ACA expansion but grants Medicaid eligibility to adults with income up to 100% FPL. Oklahoma, which expanded Medicaid beginning in July 2021, and Missouri, which will begin covering new Medicaid expansion enrollees in October, are included.)

These twelve states – Alabama, Florida, Georgia, Kansas, Missouri, Mississippi, North Carolina, Oklahoma, South Carolina, South Dakota, Tennessee, Texas and Wyoming – accounted for 1.55 million new enrollees during the SEP, or 55% of all new enrollees nationally.

In the non-expansion states, eligibility for marketplace subsidies begins at 100% FPL, as opposed to 138% FPL in Medicaid expansion states, where adults below that threshold qualify for Medicaid. Accordingly, in these states, about half of enrollees qualified for free high-CSR coverage, reporting incomes between 100% and 150% FPL. In these states, enrollment as of August 2021 (6.0 million) was 44% above enrollment in August 2019, the last pre-pandemic year (4.2 million).

More than 2 million people in non-expansion states are estimated to be stuck in the coverage gap – ineligible both for Medicaid and for ACA premium subsidies. For people in these states, reporting an income just below or just above 100% FPL ($12,760 for an individual, $26,200 for a family of four) is the difference between receiving no help at all and having access to free Silver coverage with high CSR and low out-of-pocket costs.

It’s important to keep in mind that the application for marketplace coverage requires an income estimate – and many people, unaware of the minimum income requirement, underestimate their potential income. For tips on how to make sure you leave no stone unturned in seeking help paying for coverage, see this post.

What do these numbers mean for 2022 open enrollment?

As open enrollment for 2022 approaches (it begins on November 1), the subsidies enhanced by the ARP remain in place for 2022. As Congress hashes out new investments for coming years in a pending budget bill, the pressure is intense to keep this good thing going in future years.

As of now, with the sad exception of those stuck in the coverage gap in states that still refuse to enact the ACA Medicaid expansion, any citizen or legally present noncitizen who lacks access to other forms of affordable coverage should be able to find it in the marketplace. If you need coverage, make sure to check out your options on HealthCare.gov or your state exchange.

The word that ACA marketplace plans are more affordable than ever has not yet reached many of the people who need coverage and qualify for premium subsidies. The Kaiser Family Foundation estimated in May that nearly 11 million uninsured people were subsidy-eligible. ACA enrollment assisters consistently report that many people who are eligible for coverage have no idea what’s on offer.

The Biden administration is trying to change that: after years of radical cuts in federal funds for enrollment assistance, the administration this year has allocated a record $80 million to fund nonprofit enrollment “navigator” groups charged with outreach as well as enrollment assistance. The Urban Institute forecast that if the ARP subsidies are made permanent – solidifying the perception that truly affordable coverage is here to stay — enrollment would increase by more than 5 million in 2022.

The emergency SEP provided a jump start, boosting coverage as of August more than 1.5 million above the August 2020 level. In a fraught and complex legislative session, Congress will most likely – though not certainly – do its part and extend the subsidies beyond 2022. There is certainly room for enrollment to run higher in the open enrollment season that begins on November 1.

Andrew Sprung is a freelance writer who blogs about politics and healthcare policy at xpostfactoid. His articles about the Affordable Care Act have appeared in publications including The American Prospect, Health Affairs, The Atlantic, and The New Republic. He is the winner of the National Institute of Health Care Management’s 2016 Digital Media Award. He holds a Ph.D. in English literature from the University of Rochester.