Health Issues

After months of stalled development, laws that would extend the American Rescue Plan’s overall health insurance coverage subsidy enhancements is again on the desk in the U.S. Senate. That is excellent information for the 13 million Us citizens who are suitable for premium tax credits (subsidies) that offset the price tag of marketplace (exchange) well being insurance plan.

The Inflation Reduction Act was announced in late July, and a vote in the Senate is anticipated next week. The legislation – which is both equally a weather and healthcare monthly bill – addresses numerous urgent priorities, including a a few-calendar year extension of the subsidy enhancements shipped by the American Rescue Approach.

Entire-selling price premiums will however adjust in 2023 throughout additional than 50 percent the states so considerably, the general proposed regular rate boost is about 8% – substantially of which is not associated to whether the ARP subsidies are prolonged. But most enrollees do not spend entire value. In 2022, about 89% of market enrollees receive premium subsidies. HHS estimates that 3 million men and women will get rid of their coverage completely – even though 10 million will see their subsidies decline or disappear – if the ARP subsidies are not extended below the Inflation Reduction Act.

To be obvious, even if the Inflation Reduction Act is enacted, there will be fluctuations in subsidy quantities and just after-subsidy premiums for renewing options. This comes about every year, depending on how significantly the benchmark quality improvements (preserving in mind that the benchmark system can be a unique system from a person year to the up coming) and how considerably the value of a specific approach modifications.

But with the Inflation Reduction Act, in general affordability will stay the identical as it is this yr, as the benchmark prepare would continue on to expense the exact percentage of money that individuals fork out this year. (We do have to keep in head that the benchmark program can be a distinctive program from a single 12 months to the up coming, new ideas may well be offered for the coming year, and fees for other plans relative to the benchmark plan can also adjust.)

Without the need of the Inflation Reduction Act, coverage would become a great deal considerably less cost-effective in 2023. HHS calculations exhibit that if the ARP subsidy enhancements hadn’t been in impact this yr, the premiums that enrollees paid out by themselves – just after subsidies have been used – would have been 53% bigger in the 33 states that use Healthcare.gov. That’s the sort of scenario that hundreds of thousands of marketplace enrollees would see in 2023 without the need of the Inflation Reduction Act.

But this normally differs from a person location to another depending on factors this kind of as new insurers moving into a sector, or point out reinsurance packages that deliver down total-cost costs and consequence in reduce subsidies. Even with the Inflation Reduction Act in location, that sort of subsidy and high quality fluctuation will however happen in some areas and for some strategies.

If the Inflation Reduction Act does not go, web rates will increase sharply for most present-day enrollees when their protection renews for 2023. Some enrollees will need to switch to lessen-price tag options in get to keep their rates affordable.

Irrespective of regardless of whether the ARP subsidy enhancements continue into 2023 or expire at the stop of 2022, it will be essential to diligently consider all alternatives throughout open enrollment. There will be shifting insurer participation in some spots, changing rates, and new program models.

People who purchase their personal wellness coverage will need to have to consider all of the out there designs and pick out the a person that finest fits their needs and budget. That could or may possibly not be the same prepare they had this calendar year, regardless of what happens with the ARP subsidy enhancements.

Louise Norris is an specific well being insurance policies broker who has been crafting about wellness insurance plan and health and fitness reform given that 2006. She has prepared dozens of viewpoints and academic parts about the Inexpensive Treatment Act for healthinsurance.org. Her point out health trade updates are consistently cited by media who go over health and fitness reform and by other health and fitness coverage authorities.

For many of the 155 million Americans who get their health insurance through an employer, the employer-sponsored plan feels like a security blanket. Look closely, as circumstances may well force you to, and the blanket may be full of holes. Tales of woe from patients who need intense care are plentiful – involving prior authorization hurdles, outright coverage denials for needed care or drugs, and until recently, surprise bills from out-of-network doctors or providers at in-network facilities (Congress at last banned most such billing in the No Surprises Act, effective January 1 of this year). High and rising deductibles, out-of-pocket maximums, and premiums also cause financial hardship for millions of mostly low-income workers.

Still, for the majority of employer plan enrollees whose plans cover about 85% of medical costs while the employer foots the lion’s share of the premium, the health insurance they have is not much of a worry. And people fear losing it.

That was my situation until this spring. While I am self-employed, my wife Cindy has worked at the same hospital for 25 years, which has provided family insurance. In that time we’ve been blessed with pretty good health, and when we’ve needed care, we’ve obtained it without significant hassle, including an operation to remove half my thyroid back in 2004.

Over the years our share of the premium crept up slowly, then jumped from about $200 a month to about $400 in 2016 when Cindy cut back her weekly work hours from 36 to 30 so she could help take care of her 90-something father. It’s now at about $450/month, which is manageable.

Into an ACA marketplace enhanced by the American Rescue Plan

But change comes. Cindy is retiring this month, a little shy of her 64th birthday. The Affordable Care Act was supposed to make this feasible – and since March of last year, when the American Rescue Plan provided a major boost to premium subsidies in the ACA’s health insurance marketplace, the ACA has a far more credible claim than previously to reducing “job lock.”

The ARP subsidy boosts only extend through 2022. Democrats in Congress have intended to extend them further, but with their Build Back Better legislation long stalled, extension now is far from certain.

The ARP reduced the percentage of income required to buy a benchmark Silver plan (the second cheapest Silver plan in each area) at every income level, and it removed the notorious income cap on subsidies. Before the ARP’s enactment in March 2021, people whose family income exceeded 400% of the Federal Poverty Level – currently $51,520 for an individual, $106,000 for a family of four – were ineligible for premium subsidies. Since premiums rise with age – -at age 64, they’re triple what a 21 year-old pays – paying full freight was especially challenging for 60-somethings like Cindy and me. At our age, unsubsidized benchmark premiums are typically $700-800 per month – each – and more in some states (that’s also about what COBRA would cost us).

Now, thanks to the ARP, for anyone at any income level who lacks affordable access to other insurance, a benchmark plan costs no more than 8.5% of income, and much less at lower incomes (in fact, benchmark coverage is free up to 150% FPL). The measure that determines premium subsidies is modified adjusted gross income or MAGI – basically the AGI familiar to tax filers, with a handful of additional income sources (e.g., tax exempt interest) counted.

Thanks to the ARP subsidy boost, with a large payment to my individual 401k reducing our MAGI, Cindy and I can get a benchmark Silver plan for about $400 per month. And unlike in many states, here in New Jersey the plans offered by the dominant marketplace insurers have decent provider networks.

What plan to buy? Comfort vs. math

Still, I am entering this individual insurance with some trepidation. Here’s why.

For years I’ve been closely observing and writing about the Affordable Care Act, on my blog, here at healthinsurance.org, and in various other publications. Brokers and other experts have drummed one salient fact into my head: For shoppers in the ACA marketplace with income over 200% FPL ($25,760 for an individual, $53,000 for a family of four), Bronze-level plans usually make the most economic sense. Bronze plans are the cheapest of four metal levels, and Bronze deductibles average over $7,000 for an individual, $14,000 for a family.

The picture is different for people with income under 200% FPL. Below that threshold, secondary cost-sharing reduction subsidies, available only with Silver plans and at no extra cost to the enrollee, reduce out-of-pocket costs to levels below those of the average employer-sponsored plans. CSR, which is strongest at the lowest incomes, reduces deductibles to an average below $150 at incomes up to 150% FPL and below $700 at an income in the 150-200% FPL. CSR weakens to near-insignificance at 200% FPL and phases out entirely at 250% FPL. While less than a third the population lives in households with income below 200% FPL, more than half of ACA marketplace enrollees do.

At higher incomes, Silver plan deductibles average more than $4,700, though in many plans a number of services, including doctor visits, are not subject to the deductible. That’s considerably lower than the Bronze average (over $7,000) – but generally not enough to justify the difference in premiums. That’s especially true because the annual out-of-pocket (OOP) maximum in Silver plans without CSR (that is, all Silver plans for people with income above 250% FPL) is generally not significantly below the Bronze plan OOP max. Both are usually north of $7,000 for an individual and often near or at the highest allowable, $8,700 per person.

Because premiums rise with age, the field tilts further toward Bronze plans for older enrollees. As the premium for a benchmark Silver plan rises, so does the subsidy, since all enrollees with the same income pay the same premium (a fixed percentage of income) for the benchmark plan. As the premium rises, so does the “spread” between the benchmark premium and cheaper plans. While my wife and I would pay $400 a month for benchmark Silver, we can get the cheapest Bronze plan on the market (from the same insurer) for about $10 per month.

Another consideration? HSAs

Still another factor points us toward that cheaper Bronze plan: it’s a so-called high deductible health plan (HDHP) that can be linked to a tax-sheltered health savings account (HSA). These plans, which are mostly Bronze-level, conform to special IRS rules. One is that they cannot exempt any services other than the free preventive screenings mandated by the ACA from the deductible ($6,000 per person in the Bronze plan we are likely to enroll in). That increases my anxiety: we’ll be paying cash for virtually all the medical care we access, unless we get ill or injured enough to hit the deductible. At the same time, HSA-linked plans, by statute, have lower out-of-pocket maximums than most Bronze or Silver plans, topping out at $7,050 per individual. That’s better than the two cheapest Silver plans, which both have OOP maxes of $8,700 per person. Finally, HSA contributions – up to $7,300 for Cindy and me – also reduce MAGI, and so the premium we will pay, as well as our taxes.

With the HSA contribution figured in (I left it out of my income estimate), the Bronze HSA plan we’ve settled on will probably ultimately be available for zero premium. The single-person maximum exposure, $7,050, is not much higher than what we pay in premiums in our employer-sponsored plans (about $5,400 annually) – or than what we’d pay for the benchmark Silver plan, which has a higher OOP max ($17,400 for two, vs. $14,100 for the HSA Bronze).

The cheapest Silver plan available would cost us about $300 per month, with a per-person deductible of $2,500. If both of us turn out to need a lot of medical care but not too much – say, $6,000 each – we could conceivably pay less on net under that plan, which pays 60% of most costs after the deductible is met, up to the OOP cap. But the odds of that are small. And again, if one of us needs tens of thousands of dollars in care – not unusual in U.S. medicine – we’ll pay less under the Bronze HDHP plan.

The chief argument against a high deductible Bronze plan is psychological, but real. Some years ago, Dr. Ashish Jha, currently the Biden administration’s COVID-19 policy coordinator, tried a personal family experiment – enrolling in a high-deductible plan – and wrote up the results. Jha suffers from supraventricular tachycardia, a condition that makes his heart race periodically. One morning, he woke up with his heart racing, and it persisted for about a half hour. He knew that going to the ER would cost him thousands; he also knew that he would advise a patient to go. Instead he rode it out, and his heart calmed down. “I was lucky — I had rolled the dice and things had worked out,” Jha writes.

Cindy and I are both 63. That’s a bad age to be loathe to go to the ER – or to hesitate to get an unfamiliar twinge somewhere in our bodies checked out. Perhaps having money sequestered in an HSA will reduce the psychological resistance – those funds are dedicated to medical fees. But it’s still real money: if we don’t spend it, we can roll it into our retirement funds when we reach Medicare age. Being willing to spend it still requires a psychological adjustment.

If a Silver plan for $300 per month were our only choice, I’d probably be reasonably content. The prospect of paying next to nothing for an HDHP Bronze plan makes me nervous. But it’s hard to escape the math.

Assessing the ACA marketplace

Two things are notable about the private plans subsidized by the ACA as enhanced by the ARP. First, for almost all comers, plans with an affordable premium are available – in fact, Bronze plans with zero premium, or close to it, are available pretty high up the income ladder, especially for older adults. Second, out-of-pocket costs are high. At incomes over 200% FPL, it’s hard to avoid out-of-pocket maximums below $7,000 for an individual and $14,000 for a couple or family.

Why are out-of-pocket costs in these subsidized plans so high? Several reasons. First, American healthcare is just expensive – we pay almost triple the OECD average per capita, while using less care per capita than the OECD average. Second, to avoid all-out opposition to health reform from the healthcare industry (and in a failed attempt to win Republican buy-in), the Democrats who created the Affordable Care Act created a marketplace of private plans, paying commercial rates to providers – which average about twice Medicare rates for hospital payments and perhaps 130-160% of Medicare for physicians. Finally, healthcare scholars advising the ACA’s drafters believed that subjecting enrollees to high out-of-pocket costs – giving them ‘skin in the game” – was an effective way to reduce unnecessary care and so control costs (an idea substantially discredited by multiple studies indicating that enrollees faced with high out-of-pocket costs skip necessary as well as unnecessary care).

My wife and I are entering what two or three decades ago might have been understood as a moderate or even mainstream Republican health insurance utopia. We are paying close to nothing in premiums, and we are massively incentivized to save a huge chunk of our income in tax-sheltered accounts to keep it that way. The federal government is kicking in $1400 a month. We are on the hook for up to $14,100 in out-of-pocket expenses. If we’re healthy and don’t come near that threshold, we’ll pay cash for every medical service we access except for free preventive screenings.

I am very glad that the ACA was enacted and that Republicans failed to repeal it in 2017. (My personal welfare aside, the ACA’s core programs saved the country from a surge in the uninsured population during the pandemic.) As Cindy and I enter our life’s final quarter (or third, if we’re actuarially lucky), I’m grateful that affordable coverage is available in the hold-your-breath-till-Medicare years that will shield us from costs that could seriously impact our long-term financial health.

I can imagine a simpler and more cost-effective system – one that pays uniform rates to healthcare providers and offers a very short menu of affordable choices with low out-of-pocket costs to all Americans. But given the health system we have, and current political realities, my personal ask is more immediate and plausible: extend the ARP subsidy boosts. They’ve given the ACA a credible claim to live up to its name.

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.

There are a lot of factors to consider when you’re shopping for individual health insurance coverage – from premiums to deductibles to on-exchange and off-exchange and ACA-compliant (or not). If you’re shopping in the individual health insurance market, you’ll definitely be making a choice of metal tier.

And – regardless of where you shop – you’re going to end up making a decision about a type of managed care that works best for your situation. As you’re selecting a health plan – whether it’s ACA-compliant or not – you’ll notice that the plans are labeled as either an HMO, PPO, EPO, or POS.

These acronyms stand for Health Maintenance Organization, Preferred Provider Organization, Exclusive Provider Organization, and Point of Service. They are categories of managed care, which is how virtually all modern health insurance is organized.

(The alternative is an indemnity plan, which doesn’t have a provider network. Indemnity plans are almost unheard of in today’s major medical health insurance market.)

• the number of providers from which a patient can choose,
• whether the patient has to use a primary care physician, and
• whether out-of-network care is covered under the plan.
• Some managed care plans attempt to improve health quality, by emphasizing the prevention of disease.

Indemnity plans – popular before the advent of modern managed care plans – have been largely replaced by managed care plans over the last several decades, and the vast majority of privately insured Americans are in some form of managed care plan.

Even in the Medicaid and Medicare systems, managed care is playing an increasingly large role: More than two-thirds of the Americans enrolled in Medicaid were covered under private Medicaid managed care plans as of 2019. And more than 45% of Medicare beneficiaries were enrolled in private Medicare Advantage plans as of early 2022 – a percentage that has been steadily growing over the past decade.

To a large degree, the differences involve access to providers. All HMO, PPO, EPO, and POS plans have networks of medical providers (doctors, hospitals, etc.) that have a contract with the health plan in which the carrier agrees to accept a negotiated price for the services they offer. Some plans will only pay for non-emergency care if you receive care from an in-network provider, while other plans may cover some of the bill if you see an out-of-network provider.

You’ll often see simple comparison charts that show the “rules” for the different types of managed care. In a nutshell, they’ll generally say that HMOs and POS plans require a referral from a primary care doctor in order to see a specialist, while PPOs and EPOs do not, and that PPOs and POS plans cover out-of-network care, while HMOs and EPOs do not. They will also often tend to say that HMOs have lower premiums, lower deductibles, and smaller provider networks, while PPOs have higher premiums, higher deductibles, and broader networks.

In reality, the lines tend to be more blurry, and these types of plan management have evolved over time. For example, this POS plan from Blue Cross Blue Shield of North Carolina does not require a referral to see a specialist. Neither does this HMO from Friday Health plans. And while it’s often true that employer-sponsored HMOs tend to have lower deductibles and premiums and potentially smaller networks, that does not hold true in the individual/family (self-purchased) market.

It is generally true, however, that EPO and HMO plans will not cover out-of-network care unless it’s an emergency, while PPO and POS plans will provide some out-of-network coverage. But the out-of-pocket costs for out-of-network care will typically be substantially higher than the out-of-pocket costs for in-network care. For example, that POS plan from Blue Cross Blue Shield of NC has an in-network deductible of $8,700 for a single individual, but an out-of-network deductible of $43,500. And this PPO, offered by Ambetter in Oklahoma, has an in-network deductible of $8,600, but an out-of-network deductible of $20,000.

So although PPO and POS plans do generally “cover” out-of-network care, you might find that you only get a benefit from that if your out-of-network costs are particularly high. And it’s also common to see that plans with out-of-network coverage do not put any cap on total out-of-pocket costs for out-of-network care.

(The ACA requires health plans to cap out-of-pocket costs for essential health benefits obtained from an in-network provider – the cap is $8,700 this year – but there are no limits on how high out-of-network costs can be, even if the plan provides out-of-network coverage.)

Plans with lower deductibles are certainly available, although their premium costs are generally higher. But they will still tend to have much higher out-of-network deductibles. For example, this Medica PPO has an in-network deductible of just $750. But the out-of-network deductible is $9,900, and again, there is no cap on how high out-of-pocket costs can be for care received outside the plan’s provider network.

When you’re shopping for a health insurance plan – either through the health insurance marketplace or off-exchange – there are many factors to keep in mind. (This is also true if you’re selecting from among options offered by your employer, although there are likely to be far fewer choices in that case.) We’ve covered some of them here, and also have a detailed summary of things to keep in mind when deciding which metal level is right for you.

So should the HMO, PPO, EPO, or POS designation matter when you’re selecting a plan? Maybe, but it’ll depend on the specifics of the plans that are available to you and the coverage details that are important to you.

In general, you’ll want to have a general understanding of the different types of managed care, and understand whether your choice will include any coverage for out-of-network care (that’s generally only available on PPOs and POS plans). And you’ll want to make sure you understand whether your health plan will require referrals from a primary care provider. But as described below, there are several points to keep in mind as you’re comparing plans.

Also be aware of the fact that an out-of-network provider can and will balance bill you unless it’s an emergency or an out-of-network provider working at an in-network facility. (Here’s how the No Surprises Act protects consumers from surprise balance bills in those situations).

This means that although your health plan may pay for some of the service (assuming you’ve met the out-of-network cost-sharing requirements), the provider can bill you for the portion of their charges that were above the amount the health plan paid.

2. Narrowness of networks varies

All four types of managed care plans can have broad, narrow, or mid-size provider networks. Don’t assume anything. Instead, you’ll want to actively compare the provider networks of each plan you’re considering, to see whether your specific providers are in-network.

If you don’t currently have any providers, it’s a good idea to see whether each plan you’re considering has in-network hospitals and medical offices that would be convenient if you ended up needing medical care.

3. Managed care is different in the individual market

Individual/family plans aren’t the same as employer-sponsored plans, and that includes the provider networks and managed care rules. You may have had an employer-sponsored plan offered or administered by a particular insurer, but don’t assume that individual/family plans from that insurer will have the same provider network or managed care rules (for example, whether or not a referral is required).

4. Referral requirements vary

Although you may have heard that HMOs and POS plans require a referral from a primary care physician in order to see a specialist, that’s not necessarily true. Again, you’ll need to check the specifics of the plans you’re considering. (And there are pros and cons to referral requirements. On one hand, they mean an additional office visit, which adds to your costs. But on the other hand, your PCP can help to ensure that you’re seeing the correct specialist, and can coordinate the care you receive from multiple specialists.)

Referrals are sometimes confused with prior authorizations (pre-authorizations), but those are two different concepts. A referral comes from a primary care physician, whereas prior authorization has to be obtained from the health plan itself. Health plans can set their own rules in terms of which services require prior authorization. All four types of managed care plans — HMOs, PPOs, EPOs, and POS plans — can and do require prior authorization for various services. But there’s a lot of variation from one plan to another in terms of what services need prior authorization.

So it’s important to understand your plan’s rules, and to ensure that your doctor has your health plan information so that they can submit prior authorization requests on your behalf. And if in doubt, it’s best to contact your health plan before a particular service is scheduled, to make sure you know whether prior authorization is necessary, and if so, whether it has been granted.

If you’ve read this far, you may be wondering why a health savings account (HSA) isn’t listed here. It’s common to see comparison charts that include PPO, EPO, HMO, POS, and HSA (Health Savings Account). That leads many consumers to assume that the HSA acronym is a form of managed care – but it’s not.

HSA-qualified high-deductible health plans (HDHPs) allow enrollees to contribute pre-tax money to an HSA (you cannot contribute to an HSA unless you have active coverage under an HDHP). And HDHPs must conform to specific IRS rules. The IRS sets minimum deductibles and maximum out-of-pocket limits (which are lower than the maximum out-of-pocket limits that HHS sets for other plans), and limits the services that the plan can pay for before the deductible is met.

However, HDHPs can be PPOs, EPOs, HMOs, or POS plans. So this is an “and” scenario, rather than an “or” scenario. An HDHP will also be either a PPO, HMO, EPO, or POS plan.

The HDHP designation means that the plan conforms to the IRS rules for HSA-qualified plans. And the HMO, PPO, EPO, or POS designation describes the plan’s approach to managed care.

Don’t hesitate to ask questions about your managed care options

As always, you can turn to a broker or navigator if you need assistance with the process of comparing health plans and picking the one that will best meet your needs. Depending on when you’re applying for coverage, our guide to open enrollment and our guide to special enrollment periods will answer many of your questions.

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.

When shopping for a health plan in the ACA marketplace, it’s important to recognize that while Bronze, Gold and Platinum plans have the same value no matter who is shopping, the value of Silver plans varies with income. Accordingly, the metal level that will best suit your needs is also likely to vary with income.

A lot of factors may affect your choice of metal level – your health, locality (offerings and premiums vary a lot by state and even zip code) and risk tolerance among them. But very generally speaking, Silver is almost always the best choice at low incomes, while discounted Bronze or Gold plans often make sense at higher incomes. Below, we’ll examine how income affects choice at different levels, as well as why Bronze and Gold plans are discounted to varying degrees in the current marketplace.

At first glance, the metal level system looks simple. It’s based on actuarial value (AV), which is the percentage of a standard population’s total costs that a plan is designed to cover, according to a formula provided by the federal government. Bronze plans have an AV of roughly 60%, Silver 70%, Gold 80%, and Platinum 90%.

But a subsidy called cost-sharing reduction (CSR) is available at low incomes, and only with Silver plans. CSR raises the AV of a Silver plan to 94% at incomes up to 150% of the Federal Poverty Level (currently $19,320 per year for an individual, $39,750 for a family of four), and to 87% at incomes in the 150-200% FPL range ($25,760 for an individual, $53,000 for a family of four). CSR fades to near insignificance at the 200-250% FPL level, and is not available at incomes over 250% FPL.

The American Rescue Plan, which lowered premium subsidies at all income levels through 2022, made a benchmark Silver plan (the second cheapest Silver plan) free at incomes up to 150% FPL. That makes it almost inconceivable that another metal level makes sense for an enrollee with an income below this threshold. (There’s a good chance that Congress will extend the enhanced subsidies beyond 2022, but it’s not a sure thing.)

Boosted by the highest level of CSR, Silver plans at this income level have deductibles averaging about $160 and an annual out-of-pocket (OOP) max of about $1,200. Bronze plans have deductibles averaging over $7,000 and OOP maxes ranging from about $7,000 to the highest allowable, $8,700. Gold plan deductibles average $1,600, and Gold OOP maxes are usually above $5,000.

At an income in the 150-200% FPL range, Silver plans still usually make the most sense. A benchmark Silver plan in this income range costs 0-2% of income, topping out at $43/month for a single individual. Deductibles at this second level of CSR average about $660 and OOP maxes about $2,600.

Bronze plans are generally available for free at this income level – but their deductibles average ten times as high as those of Silver plans in this income bracket and their OOP maxes are about triple.

Gold plans in some states and regions cost less than Silver plans (more on that below), and in this 150-200% FPL bracket, they too may sometimes be free. But they have a lower actuarial value than Silver plans in this bracket (80% AV, compared to 87% for Silver with CSR), and their OOP maxes are usually at least twice as high as the highest allowable for Silver.

A Gold plan could sometimes make sense for a buyer in this income bracket – for example, if it costs less than a Silver plan from the same insurer, and that insurer has a good provider network. But Silver is almost always the right choice at incomes up to 200% FPL.

Trump’s move had been expected, and analysts forecasting the likely effects (including the Congressional Budget Office) expected that Gold plans would be consistently priced below Silver. A majority of marketplace enrollees, and a large majority of Silver plan enrollees, have incomes below 200% FPL, and so get Silver with AV of 94% or 87%. On average, then, Silver plan AV is well above Gold’s 80%. It should be priced above Gold.

But Silver loading stopped halfway. Competitive pressures led insurers in many markets to underprice Silver, since most enrollees have incomes below 200% FPL, and the lowest-cost Silver plans are the most popular. Discounts generated by Silver loading have been partial and haphazard. But they exist to some degree in every market. Generally, if you buy a Silver plan and you have an income where CSR is weak or not available, you’re paying for CSR that you don’t get

In some states, a monopoly insurer or dominant insurer has priced Gold plans below – sometimes well below – the Silver benchmark. This also happens in scattered regions of other states. In a few states, regulators have required insurers more or less directly to price Silver in a way that reflects the value of CSR, ensuring that Gold plans will be available at a premium below the Silver benchmark, and that Bronze plans will be heavily discounted. States that shape their markets in this way include Maryland, Pennsylvania, Virginia, New Mexico and, starting in 2023, Texas.

Let’s look at how choices shape up in some of these markets. It’s worth noting that while deductibles in the ACA marketplace tend to be high at incomes above 200% FPL, Silver and Gold plans often exempt many services – including doctor visits – from the deductible. Bronze plans sometimes do this too, though in a more limited fashion. Also worth noting: there’s often a tradeoff between the deductible and the annual out-of-pocket (OOP) maximum that enrollees can be charged for in-network services.

In each case below, we’ll look at pricing for a single 47 year-old (the median adult marketplace age) with an income of $33,000 – too high to qualify for CSR. At that income, a benchmark Silver plan costs $117 per month – everywhere.

There’s a catch, though: this low-cost Gold plan is designed so that an enrollee would be allowed to contribute to a health savings account (HSA). This means it’s subject to a set of rules that forbid any services to be provided that are not subject to the deductible, with the exception of the free preventive services mandated for all plans by the ACA. For some enrollees, this could be a drawback. But for those who want to be able to make pre-tax contributions to an HSA, the availability of a low-cost HSA-qualified plan will be a boon.

A Highmark Gold plan, for $88 a month, has a $0 deductible but an OOP max of $7,500. The cheapest Bronze plan is effectively free, with a deductible of $6,700 and an OOP max of $8,700.

These choices are complex, no getting around it. But Gold options clearly trump the Silver. Free Bronze might make sense for some – if they can cover several thousand dollars in unexpected expenses in the event of an unforeseen accident or illness.

The cheapest Bronze plan in this market is an HSAl-qualified plan available for $5 per month, with a $6,900 deductible and OOP max. For $19/month, a UHC Bronze plan has a $6,100 deductible, and doctor visits not subject to the deductible ($40 for primary care, $70 for a specialist).

Three Bronze plans are available in the Albuquerque market at less than $1 per month, and two more at less than $30 per month. Most of these plans offer doctor visits and/or generic drugs not subject to the deductible.

As the choices above illustrate, many factors besides premium and deductible should be considered while choosing a plan. The OOP max looms especially large for people who know they will need significant medical care – and as a risk factor for the healthy. Plans with more robust provider networks generally cost more than narrow network plans. The patchwork of cost-sharing for doctor visits, drugs, imaging and tests is also part of the mix, and those who expect to need certain services should check cost-sharing for them in those plans that they are considering.

Since premiums rise with age, so do the discounts on plans that cost less than the Benchmark Silver plan, as the “spread” between the benchmark and the cheaper plan increases proportionately. In states and regions where Gold plans do not cost less than the Benchmark, this makes Bronze plan discounts really salient for older enrollees – especially those who either don’t expect heavy medical costs or those who know that they will likely reach an out-of-pocket maximum with any plan. For people with enough savings to cover an OOP maximum in a bad year ($8,700 is the highest allowable in 2022), zero- or low-premium Bronze is often a viable option.

As New Mexico’s plan menu illustrates most clearly, the high value of CSR-enhanced Silver plans at low incomes should lead to discounted Gold and Bronze options for people with higher (often only modestly higher) incomes. The federal government could shape the national market to look more like New Mexico’s. If that doesn’t happen, other states are likely to follow New Mexico’s example, as Texas has for 2023.

Bottom line: if your income is below 200% FPL, you’re almost certainly best off in a Silver plan. If it’s above that threshold, look for discounts in Gold and Bronze. While only a few states have taken positive action to maximize those discounts, they exist to varying degrees in most markets.

—

* PA’s regulatory scheme fails in the Philadelphia area, where the dominant insurer, Independence Blue Cross, skirts the regulation by not offering a Gold plan with the same provider network as its cheapest Silver plan. Ambetter, a cut-rate insurer, follows suit, to a more moderate degree: its cheapest Gold plan is $130/month, $13 above benchmark.

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.

In the 2022 open enrollment period for ACA marketplace plans, more Americans enrolled than in any previous year. An estimated 14.5 million people obtained 2022 marketplace coverage, an increase of 21% over 2021. And 89% of them were subsidized, with the federal government paying more than 80% of the premium on average in the 33 states that use HealthCare.gov, the federal platform.

The increased enrollment was mainly due to a boost to premium subsidies provided last March by the American Rescue Plan. (The boost extends only through 2022 and subsidy increases will expire next year unless Congress extends them.) The ARP did away with the ACA’s notorious subsidy cliff, which cut off subsidy eligibility at 400% of the Federal Poverty Level ($51,040 for an individual, $104,800 for a family of four in 2022). The ARP also reduced the percentage of income required to pay for a benchmark Silver plan (the second cheapest Silver plan in each area) at every income level.

In fact, the ARP made a benchmark Silver plan free at incomes up to 150%  FPL. A third of all marketplace enrollees – 4.6 million – have incomes below that threshold ($19,320 for an individual, $26,130 for a couple, $39,750 for a family of four).

That’s really good news. But not every low-income enrollee obtained the full value of the coverage available to them. A substantial number chose or remained enrolled in Bronze plans with much higher out-of-pocket costs.

At incomes up to 250% FPL, Silver plans are enhanced by cost-sharing reduction, which reduces out-of-pocket costs. CSR is particularly strong at incomes up to 150% FPL, where it reduces the average deductible to $146 and the average annual out-of-pocket maximum – the most an enrollee will pay for in-network care – to $1,208. Bronze plans – in prior years usually the only free option – have deductibles averaging $7,051 and OOP maxes usually in the $7,000-8,700 range.

Thanks to the ARP, every ACA market now has two Silver plans that are free to people with incomes up to 150% FPL, and often several more with single-digit premiums. Still, more than 600,000 enrollees with income below the 150% FPL threshold – 14% of enrollees in that income category – are enrolled in Bronze plans. Many of them may have been enrolled in those Bronze plans in 2021, when Silver plans were rarely free, and let themselves be passively auto-renewed, which happens if you take no action during the open enrollment period.

A small percentage of enrollees with income under 150% FPL may be ineligible for premium subsidies – for example, if they have an offer of insurance from an employer that’s deemed affordable by ACA standards but for some reason prefer to pay full cost for a marketplace plan. But the vast majority of the 618,575 low-income enrollees in Bronze plans are leaving serious money on the table – or, more exactly, exposing themselves to serious costs if they prove to need significant medical care.

At low incomes, a new opportunity to switch to Silver

Fortunately, if you find yourself in this situation – enrolled in a Bronze plan while a free high-CSR Silver plan is available to you – CMS (U.S. Centers for Medicare & Medicaid Services) has created a remedy that went into effect just this March. As Louise Norris recently explained on this site:

In September 2021, the U.S. Department of Health & Human Services finalized a new special enrollment period (SEP) in states that use HealthCare.gov (optional for other states), granting year-round enrollment in ACA-compliant health insurance if an applicant’s household income does not exceed 150% of the federal poverty level (FPL) and if the applicant is eligible for a premium tax credit (subsidy) that will cover the cost of the benchmark plan.

This SEP became available on the HealthCare.gov website (and enhanced direct enrollment entity websites) as of March 21, 2022.

Some but not all of the 18 state-based exchanges are currently offering this SEP. Several don’t need to, because they offer another type of free health insurance (Medicaid or a Basic Health Program) to enrollees with incomes up to 150% FPL or higher. See the note at bottom for details.

This newly instituted SEP also allows current enrollees with income below the 150% FPL threshold to switch into a Silver plan at any time. In fact, enrolling low-income people in Silver plans specifically is an express goal of the department of Health and Human Services, spelled out in its finalization of the rule establishing the SEP:

HHS proposed making this special enrollment period available to individuals based on household income level because enhanced financial assistance provided by the ARP for tax years 2021 and 2022 is such that many individuals with a household income no greater than 150 percent of the FPL have access to a silver plan with a zero dollar monthly premium.

If your income is below 150% FPL in particular, HHS wants you in a Silver plan:

… enrollees with a newly-enrolling dependent or other household member may not use the new monthly special enrollment period to change to a plan of a different metal level other than a silver-level QHP to enroll together with their newly-enrolling household member, but can stay in the same plan or change to a silver plan to enroll together with the newly-enrolling household member.

There is one downside to switching to a Silver plan during the plan year: any money you’ve already spent this year on medical care will not count toward your new deductible and out-of-pocket max. But the deductible, OOP max and copays or coinsurance are generally so much lower in Silver plans than in Bronze that this will rarely be a deterrent – unless you have already spent enough to have reached or nearly your current plan’s OOP max.

Bottom line: if your income is below the 150% FPL threshold (again: $19,140 for a single person, $32,580 for a family of four) and you are enrolled in a Bronze or Gold plan, strongly consider switching to Silver. The new SEP for low incomes makes switching easy.

SEP varies in state-based exchanges (SBEs)

Our prior post about the SEP for enrollees with income up to 150% FPL explains:

State-run exchanges (there are 18 as of the 2022 plan year) are not required to offer this SEP. But as of early 2022, several state-run exchanges (Colorado, Maine, Pennsylvania, New Jersey, California, and Rhode Island) had already debuted the new SEP.

Several other state-run exchanges have no need for this SEP, because they have other programs with year-round availability. This includes:

• New York and Minnesota, both of which have Basic Health Programs that cover people with income up to 200% of FPL
• Massachusetts, which offers Connector Care to people with income up to 300% of FPL (enrollment is open year-round to people who are newly eligible or who have not been covered under the program in the past)
• DC, which offers Medicaid to adults with income up to 215% of the poverty level

Some of the remaining state-run exchanges may decide to allow this SEP as of 2022, and others may choose not to offer it at all. Some state-run exchanges may find that it’s too operationally challenging to make this SEP available for 2022, and may postpone it until 2023 (assuming that the ARP’s subsidy enhancements are extended).

State-run exchanges have flexibility in terms of how they implement this SEP.

As noted above, some may choose not to offer this SEP at all. For those that do offer it, proof of income might be required in order to trigger the SEP, or they may follow the federal government’s lead and allow the SEP eligibility to be based on the income attested by the consumer.

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.

During the open enrollment period for 2022 health coverage, more than 14.5 million Americans enrolled in private health plans through the health insurance marketplaces nationwide. That was a record high, and a 21% increase over the number of people who enrolled the previous year.

The open enrollment period for 2022 was a month longer in most states, and the federal government spent significantly more money on outreach and enrollment assistance. But the primary factor driving the enrollment growth was affordability. Thanks to the American Rescue Plan (ARP) – which took effect last spring – self-purchased coverage is a lot more affordable for most people than it used to be.

Unfortunately, the improved affordability is currently set to expire at the end of 2022. Unless Congress takes action to extend the subsidy enhancements made by the ARP, the subsidy structure will revert to the basic Affordable Care Act subsidies as of January 1, 2023.

Although the Congressional Budget Office projected last year that the enhanced subsidies would increase marketplace enrollment by 1.7 million Americans in 2022, enrollment actually grew by 2.5 million people. Again, some of that was due to the longer open enrollment window and the additional federal funding for enrollment assistance and outreach. But the improved affordability of marketplace coverage is the primary reason for the enrollment growth.

If the ARP subsidy enhancements are not extended, nearly everyone with marketplace coverage will have to pay higher premiums next year. And the 2.5 million additional enrollees who signed up this year may no longer be able to afford their coverage in 2023.

The subsidy cliff would return, as subsidies would no longer be available to households that earn more than 400% of the federal poverty level. As we’ve explained here, some Americans with household income a little over 400% of the poverty level had to pay a quarter – or even half – of their annual income for health insurance before the ARP’s subsidy structure was implemented.

That’s untenable, obviously. (Before the ARP, people in that situation often went uninsured or relied on less expensive options that are not comprehensive coverage – such as a health care sharing ministry plan or short-term health insurance.)

If the ARP’s subsidy enhancements expire, coverage will also become less affordable for people with income below 400% of the poverty level. Although most of them will continue to be subsidy-eligible, their subsidy amounts will drop, leaving them with higher net premiums each month. This chart shows some examples of how the ARP increased subsidies; those subsidy boosts will disappear at the end of this year unless Congress passes legislation to extend them.

Across the 10.3 million people who enrolled through the federally run exchange (HealthCare.gov, which is currently used in 33 states), the average net premium this year is $111/month. HHS noted that without the ARP’s subsidy enhancements, the average net premium would be $170/month, so the ARP is saving the average enrollee $59 per month in 2022. At ACA Signups, Charles Gaba has some alarming graphs showing just how much more people will be paying for their health insurance if the subsidy enhancements aren’t extended.

And across all 14.5 million exchange enrollees this year, 66% are enrolled in Silver or Gold plans, versus 63% in early 2021 (prior to the ARP). Some of the people who were previously enrolled in Bronze plans have shifted to more-robust Silver and Gold plans this year.

Although those percentages are still in the same ballpark, we also have to remember that enrollment is considerably higher this year. The result is that 2 million additional people have coverage under robust Silver and Gold plans this year (9.6 million, versus 7.6 million last year). This is a direct result of the additional affordability created by the ARP’s subsidy enhancements. People generally prefer the most robust coverage that they can realistically afford, and the ARP made it easier to afford better coverage.

It’s particularly important to point out that the ARP subsidies allow people with income up to 150% of the poverty level to enroll in the benchmark Silver plan for free (for 2022 coverage, 150% of the poverty level is $19,320 in annual income; for a family of four, it’s $39,750). For these enrollees, robust cost-sharing reductions make these Silver plans better than a Platinum plan, with very low out-of-pocket costs. Prior to the ARP, people in this income range had to pay premiums of up to about 4% of their income for the benchmark plan. And without the ARP’s subsidy enhancements, many of these people would be unable to afford the coverage they have this year.

The availability of free Silver plans for this population has proven to be especially important in the dozen states that have not expanded Medicaid, since people in those states are eligible for marketplace premium subsidies with income as low as 100% of the poverty level (in states that have expanded Medicaid, Medicaid is available to people with income up to 138% of the poverty level, resulting in a much smaller segment of low-income enrollees being subsidy-eligible). Although enrollment in marketplace plans grew by 21% nationwide in 2022, the most significant growth tended to be concentrated in the states that have not expanded Medicaid, where it grew by an average of 31%.

If Congress doesn’t take action to extend the ARP’s subsidies, all of these gains will be lost. Millions of people will lose their coverage or be forced to shift to less robust coverage, because their current coverage will no longer be affordable in 2023.

It’s also worth noting that the new special enrollment period for people with income up to 150% of the poverty level would expire at the end of 2022 if the ARP’s subsidies are not extended. When HHS created this special enrollment period, they clarified that it will only remain in effect as long as people in that income range can enroll in the benchmark plan without paying any premiums.

Without the ARP’s subsidy enhancements, that would no longer be the case.

Last fall, the U.S. House of Representatives passed the Build Back Better Act, which called for a temporary extension of the ARP’s subsidy enhancements. Under that legislation, the larger and more widely available subsidies would have continued to be in place through 2025 (instead of just through 2022), and the legislation also called for a one-year extension of the ARP’s subsidy enhancements for people receiving unemployment compensation.

Unfortunately, the legislation stalled in the Senate, after being opposed by all 50 Republican Senators, as well as Sen. Joe Manchin, a Democrat from West Virginia. So the subsidy enhancements for Americans receiving unemployment compensation expired at the end of 2021, and the rest of the ARP’s subsidy enhancements are currently slated to expire at the end of 2022.

The Build Back Better Act is a massive piece of legislation, addressing a wide range of issues and costing more than $2 trillion. But Sen. Manchin supports the extension of the ARP’s subsidies, which means a smaller piece of legislation addressing just this issue would be likely to garner his support.

States can have insurers file two sets of rates for 2023, or file a single set of rates that explain whether they’re assuming the ARP subsidies will expire or be extended (Missouri is an example of a state taking this approach). Some states will tell insurers to simply base their rate filings on the current situation — ie, that the ARP subsidies will not exist in 2023 — and deal with potential revisions later on (Virginia is an example of a state that has instructed insurers to file rates based on the assumption that the ARP subsidies will expire at the end of 2023; this was clarified in a recent teleconference hosted by the Virginia Bureau of Insurance).

States and insurers have previously demonstrated the ability to turn on a dime, as we saw with the rate revisions that were implemented in many states in October 2017, after federal funding for cost-sharing reductions was eliminated at the eleventh hour. So if the ARP subsidies are extended mid-way through the rate filing/review process, insurers will be able to revise their rates accordingly, even at the last minute.

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.

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.