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Why your ACA premium might be going up for 2022


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


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

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

What affects fluctuations in what you pay for insurance premiums?

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

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

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

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

Anatomy of a drastic increase in premium payment

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

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

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

New health plan options can affect benchmark plans – and your subsidies

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

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

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

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

The perfect storm for a large net rate increase?

That’s a perfect storm for a large net rate increase: The benchmark premium has dropped by $182/month while her health plan’s rate has increased by $56/month.

In 2021, Medica offered both the lowest-cost and second-lowest-cost Silver plan in Lincoln, and there was a significant difference in price between the two plans ($504/month for the lowest-cost, versus $657/month for the second-lowest-cost). Monique’s plan was the lowest-cost Silver option, and the large difference in premium between her plan and the benchmark plan explained why she was able to enroll in her plan with no premium at all. all. (A spread that big between the two cheapest Silver plans is unusual and creates a huge discount for the cheapest Silver plan when it happens.)

But that’s no longer the case for 2022. Ambetter has the four lowest-cost Silver plans in the area, and there’s only a $17 difference in price across all four of them. The two lowest-cost Silver plans are actually priced at exactly the same amount. As a result, the cheapest Silver plan that Monique can get for 2022 is going to be $141/month.

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

You may not be stuck with that higher 2022 premium.

The good news for Monique is that she’s not stuck with her new $226/month premium. There are 15 Silver plans that are less expensive than that for 2022, and there are also 43 Bronze plans that are less expensive, including several that are under $50/month. Bronze plans do tend to have fairly high out-of-pocket costs. But Monique can select from among three Bronze plans offered by Bright Health that include pre-deductible coverage for things like primary care visits, outpatient mental health care, and urgent care visits, with monthly premiums that range from $18 to $42.

Although those Bright Health Plans do have deductibles that are higher than her current Medica plan, she might find that she comes out ahead on out-of-pocket costs due to the more robust pre-deductible coverage that they provide. And that might be especially true when she factors in the premium savings: A plan that costs $18/month will save her more than $200/month in premiums, compared with renewing her current plan.

The takeaway point here is to not panic if your plan’s premium is increasing by a lot more than you might have expected. Even if your rate is increasing significantly, you might find that there are other options available that will be a better fit for your budget.

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

How to find solid replacement coverage with a lower net premium

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

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

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

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


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

 





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Four reasons to not wait until January to enroll in an ACA health plan


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

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

Which states have open enrollment dates past December 15 – but continue to have January 1 efficient dates?

There are some exceptions, nonetheless. The next point out-operate exchanges are giving people today further time to signal up for a prepare that can take result January 1:

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

1. Presently uninsured? Delaying your enrollment will mean no protection in January.

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

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

2. Now uninsured or enrolled in a non-market plan? Delayed enrollment may imply lacking out on totally free dollars.

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

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

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

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

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

3. Allowing your plan car-renew? You might be in for a shock.

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

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

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

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

4. Out-of-pocket expenditures will not transfer in February or March.

What if you are enrolled in a marketplace prepare in 2021, allow it automobile-renew for 2022, and then make your mind up immediately after December 15 that you’d somewhat have a distinctive system? Many thanks to the prolonged open enrollment interval, you can do that, and your new prepare will choose impact in February (or possibly March, if you are in one of the state-operate exchanges with the newest enrollment deadlines).

But it’s crucial to have an understanding of that you are going to be starting off over with a new program in February or March. This implies the out-of-pocket fees counted from your deductible and out-of-pocket highest will reset to $, even if you finished up with out-of-pocket expenses in January.

Out-of-pocket bills reset to $ on January 1 for all marketplace programs, so your car-renewed plan will start off about with a new deductible at that level. But if you require medical treatment in January (and have involved out-of-pocket costs) before your new program will take impact in February, you will possibly have a increased out-of-pocket publicity for the full 12 months than you would have if you’d picked your new program by December 15 and experienced it start off January 1.

All of this is a reminder that even though most enrollees have until finally at least mid-January to indication up for 2022 coverage, it is in your greatest curiosity to get your system range sorted out by December 15.


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





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Think you’re not eligible for ACA subsidies? Think again.


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

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

Millions have now tapped into the subsidies

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

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

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

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

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

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

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

1. The uninsured – qualified for very low-value or NO-expense protection

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

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

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

2. Customers enrolled in non-ACA-compliant strategies

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

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

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

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

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

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

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

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

3. Purchasers enrolled in off-trade overall health programs

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

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

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

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

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

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

4. Individuals enrolled in on-trade ideas, but no money information on file and no modern coverage reconsiderations

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

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

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

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

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

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

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


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



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Congress boosted ACA subsidies. An enrollment surge followed.


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

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

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

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

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

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

ARP prompted an enrollment surge during the 2021 SEP

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

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

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

Savings were also dramatic for existing marketplace enrollees:

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

My premium went down how much?

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

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

Which states saw the biggest gains in new enrollees?

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

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

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

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

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

What do these numbers mean for 2022 open enrollment?

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

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

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

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

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


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





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Subsidy availability drives consumers to shop for health insurance


A major premise of the Affordable Care Act (ACA) was that Americans who need to buy their own health coverage in the individual market should be able to obtain coverage – regardless of their medical history – and that the monthly premiums should be affordable.


The rules to facilitate those goals have been in place for several years now. And although they have worked quite well for some Americans, there have been others for whom ACA-compliant health coverage was still unaffordable.

But the American Rescue Plan, enacted earlier this year, has boosted the ACA’s subsidies, making truly affordable coverage much more available than it used to be.

The numbers speak for themselves: Exchange enrollment has likely reached a record high of nearly 13 million people in 2021, after more than 2.5 million people enrolled during the COVID/American Rescue Plan enrollment window, which ended this month in most states.

How much are consumers saving on health insurance premiums?

And the amount that people are paying for their coverage and care is quite a bit lower than it was before the APR’s subsidy enhancements. We can see this across the states that use the federally run exchange (HealthCare.gov), as well as the states that run their own exchanges:

  • Among the people who enrolled during the recent special enrollment period in the 36 states that use HealthCare.gov, average after-subsidy premiums were 27% lower than the amounts people were paying pre-ARP.
  • Among HealthCare.gov enrollees who signed up during the special enrollment period or who updated their enrollments to claim the enhanced subsidies, 35% are now paying less than $10/month for their coverage.
  • Average deductibles for new HealthCare.gov enrollees were 90% lower than pre-ARP deductibles, likely driven in large part by the number of people who were able to enroll in free or low-cost Silver plans with built-in cost-sharing reductions. (This includes people receiving unemployment compensation in 2021, as well as people who aren’t eligible for Medicaid and whose household income is between 100% and 150% of the federal poverty level.)
  • The state-run exchange in Washington reported that 78% of their enrollees are now receiving premium subsidies, versus 61% before the ARP was implemented. And consumers with income above 400% of the poverty level, who were not eligible for subsidies pre-ARP, are now paying an average of $200 less in premiums each month. Washington’s exchange also noted that 15% of their enrollees are now paying $1/month or less for their coverage, versus only 5% whose premiums were that low pre-ARP.
  • The state-run exchange in California reported that consumers with household incomes between 400% and 600% of the poverty level are saving an average of almost $800/month on their premiums. (That’s an individual with income up to about $76,000, or a household of four with an income up to about $157,000.)
  • The state-run exchange in Nevada reported that people who enrolled or updated their account since the ARP was implemented are paying an average of $154/month in after-subsidy premiums, whereas the after after-subsidy premium at the end of last winter’s open enrollment period (pre-ARP) was $232/month.
  • Maryland’s state-run exchange reported a 12% increase in the number of enrollees receiving subsidies; more than 80% of Maryland’s current exchange enrollees are subsidy-eligible.

These examples highlight the improved affordability that the ARP has brought to the health insurance marketplaces. People who were already eligible for subsidies are now eligible for larger subsidies. And many of the people who were previously ineligible for subsidies — but potentially facing very unaffordable health insurance premiums — are benefiting from the ARP’s elimination of the income cap for subsidy eligibility.

How long will the ARP’s subsidy boost last?

Although the ARP’s subsidies for people receiving unemployment compensation in 2021 are only available until the end of this year, the rest of the ARP’s premium subsidy enhancements will continue to be available throughout 2022 — and perhaps longer, if Congress extends them.

This means that the affordability gains we’ve seen this year will be available during the upcoming open enrollment period, when people are comparing their plan options for 2022.

Robust ACA-compliant coverage will continue to be a more realistic option for more people, reducing the need for alternative coverage options such as short-term plans, fixed indemnity plans, and health care sharing ministry plans.

Even catastrophic plans – which are ACA-compliant but not compatible with premium subsidies – are likely to see reduced enrollment over the next year, since more people are eligible for enhanced subsidies that make metal-level plans more affordable.

Can everyone find affordable health insurance now?

Unfortunately, not yet. There are still affordability challenges facing some Americans who need to obtain their own health coverage. That includes more than two million people caught in the “coverage gap” in 11 states that have refused to expand eligibility for Medicaid, as well as about 5 million people affected by the ACA’s “family glitch.”

There are strategies for avoiding the coverage gap if you’re in a state that hasn’t expanded Medicaid, and Congressional lawmakers are also considering the possibility of a federally-run health program to cover people in the coverage gap.

Families affected by the family glitch have access to an employer-sponsored plan that’s affordable for the employee but not for the whole family – and yet the family is also ineligible for subsidies in the marketplace/exchange. (It’s possible that the Biden administration could tackle this issue administratively in future rulemaking.)

Have ARP’s subsidy boosts been successful?

With the exception of those two obstacles, the ARP has succeeded in making affordable health coverage a more realistic option for most Americans who need to obtain their own health coverage. We can see success in the record-high exchange enrollment, the increased percentage of enrollees who are subsidy-eligible, and the reduction in after-subsidy premiums that people are paying.

If you’re currently uninsured or covered by a non-ACA-compliant plan (including a grandfathered or grandmothered plan), it’s in your best interest to take a moment to see what your options are in the ACA-compliant market. Open enrollment for 2022 coverage starts in just two months, but you may also find that you can still enroll in a plan for the rest of 2021 if you live in a state where a COVID/American Rescue Plan enrollment window is ongoing, or if you’ve experienced a qualifying event recently (examples include loss of employer-sponsored insurance, marriage, or the birth or adoption of a child).

Even if you shopped just last winter, during open enrollment for 2021 plans, you might be surprised at the difference between the premiums you would have paid then and now. The ARP wasn’t yet in effect during the last open enrollment period, so if you weren’t eligible for a subsidy last time you looked, or if the plans still seemed too expensive even with a subsidy, you’ll want to check again this fall.

The subsidies for 2022 will continue to be larger and more widely available than they’ve been in the past, and you owe it to yourself to see what’s available in your area.


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.





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Lost your job? Here’s how to keep your health insurance or find new coverage now.


Most Americans under the age of 65 get their wellbeing coverage from an employer. This will make lifestyle reasonably straightforward as prolonged as you have a task that supplies good wellbeing gains: All you want to do is enroll when you’re eligible, and if your employer offers a couple options from which to select, select the a single that very best matches your needs each and every calendar year all through your employer’s annual enrollment interval.

But the draw back to getting wellness insurance policies linked to work is that getting rid of your work will also mean dropping your wellbeing insurance policy, introducing tension to an already annoying problem.

The superior information is that you have acquired selections — in all probability many, based on the circumstances. Let us just take a seem at what you want to know about health insurance policies if you’ve lost your career and are struggling with the reduction of your employer-sponsored well being protection.

Can I enroll in self-ordered insurance as quickly as I’ve dropped my career?

If you’re getting rid of your work-based health and fitness insurance, you do not have to wait around for the fall open enrollment period of time to signal up for a new ACA-compliant program.

Although the COVID-linked distinctive enrollment window for person/spouse and children wellness ideas has by now ended in most states, you are going to qualify for your individual special enrollment time period due to the loss of your employer-sponsored health approach.

This will permit you to enroll in a program by way of the market/exchange and acquire advantage of the subsidies that are offered (and even larger than ever, many thanks to the American Rescue Program), without the need of owning to hold out right until 2022 to get coverage.

If you enroll prior to your coverage reduction, your new prepare will consider outcome the initial of the thirty day period right after your previous prepare finishes, which suggests you are going to have seamless coverage if your old program is ending on the previous working day of the month.

Your particular enrollment period of time also continues for 60 times soon after your protection loss, while you’d have a gap in coverage if you wait and enroll just after your outdated strategy ends, due to the fact your new plan wouldn’t acquire influence retroactively.

If you are in that situation, you may possibly come across that a quick-time period health and fitness approach is a superior option for bridging the gap until your new approach will take outcome. Limited-phrase strategies won’t address pre-existing circumstances and are not controlled by the Economical Treatment Act (ACA). But they can deliver rather excellent protection for unpredicted health care demands for the duration of a non permanent window when you’d in any other case be uninsured.

Be guaranteed to examine your possibilities yet again for the duration of open up enrollment

If you sign up for coverage now in your distinctive enrollment time period, continue to keep in brain that you are going to even now need to re-consider your protection all through the impending open up enrollment time period, which commences November 1. Even nevertheless you’re enrolling relatively late in 2021, your new approach will reset on January 1, with new pricing and perhaps some coverage changes. There also might be new programs accessible in your place for 2022.

So your unique enrollment period of time (tied to your coverage decline) will be your possibility to locate the best strategy to match your wants for the relaxation of this year. And if you are nonetheless going to will need self-obtained coverage in 2022, the approaching open enrollment interval will give you a probability to make positive you optimize your coverage for next yr as nicely.

COBRA (or point out continuation) versus self-procured coverage

Based on the measurement of your employer, COBRA could be available to you. And even if your employer is as well compact for COBRA, you may have entry to point out continuation (“mini-COBRA”), relying on in which you are living. Either of these solutions will permit you to quickly continue on the protection you currently have, alternatively of switching to a new personal-sector prepare right absent.

If COBRA or state continuation is obtainable, your employer will notify you and give you info about what you are going to require to do to activate the coverage continuation and how lengthy you can keep it.

Usually, you have to shell out the entire expense of COBRA or state continuation protection, including the part that your employer earlier paid on your behalf — which was possible the bulk of the premiums. But until the finish of September 2021 (so for just one extra month), as portion of the American Rescue Prepare (ARP), the federal govt will fork out the full cost of COBRA or point out continuation protection for men and women who involuntarily lost their jobs.

For substantially of this yr, the shortly-to-end COBRA subsidy has adjusted the calculus that normally goes into the determination of whether or not to carry on an employer-sponsored plan or swap to a self-procured particular person/loved ones approach. But just after the stop of September, the standard conclusion-creating method will again implement. And you will have a particular enrollment period when the COBRA subsidy finishes, which will enable you to transition to an unique/relatives approach at that stage if you want to.

COBRA protection vs specific-sector wellbeing insurance coverage

Here’s what to hold in brain when you’re determining involving COBRA and an person-sector wellbeing prepare – both in the beginning, or just after the COBRA subsidy ends on September 30:

  • ACA market subsidies are now accessible at all money degrees, relying on the value of coverage in your area (the American Rescue System eliminated the cash flow cap for subsidy eligibility for 2021 and 2022). And the subsidies are considerable, covering the greater part of the high quality cost for the majority of marketplace enrollees. Unless of course your employer is continuing to subsidize your COBRA protection after the federal subsidy expires, you are going to probably find that the regular premiums are decreased if you enroll in a approach through the market, as opposed to continuing your employer-sponsored system.
  • Have you presently spent a substantial amount of money of income on out-of-pocket fees below your employer-sponsored strategy this 12 months? You are going to pretty much certainly be starting in excess of at $ if you change to an specific/household program, even if it is available by the exact same insurer that presents your employer-sponsored coverage. Depending on the particulars of your condition, the dollars you’ve by now compensated for out-of-pocket professional medical charges this calendar year could offset the reduced rates you’re probably to see in the marketplace.
  • Do you have specific medical practitioners or healthcare services you have to have to continue to use? You’ll want to very carefully test the company networks of the available unique/household options to see if they are in-community. And if there are certain medications that you need to have, you will want to be positive they’re on the formularies of the programs you are contemplating.
  • Will you qualify for a premium subsidy if you switch to an particular person/spouse and children prepare? If you do qualify, you’ll will need to store in your exchange/marketplace, as subsidies are not available if you acquire your prepare straight from an insurance company. (You can call the number at the top of this page to be linked with a broker who can assist you enroll in a program by means of the exchange.) And yet again, as a consequence of the ARP, subsidies are greater and extra widely accessible than normal that will go on to be the scenario all over 2022 as effectively.

Free of charge well being insurance plan if you gathered unemployment in 2021

If you’re approved for even one 7 days of unemployment payment in 2021, you qualify for a high quality subsidy that will fully protect the expense of the two most affordable-value Silver ideas in the market/exchange in your spot, via the close of the year.

The subsidy will also probably go over the total expense of many of the Bronze programs, and quite possibly some of the Gold plans, based on the pricing of ideas wherever you stay. This is a unique subsidy rule established by the ARP, for 2021 only.

In addition to the subsidy that will make it possible for you to get a absolutely free Silver program, it will also make sure that any of the accessible Silver programs have full expense-sharing reductions.

What if my cash flow is much too lower for subsidies?

In purchase to qualify for premium subsidies for a prepare acquired in the market, you need to not be qualified for Medicaid, Medicare, or an employer-sponsored program, and your money has to be at the very least 100% of the federal poverty amount. (As pointed out earlier mentioned, for 2021 only, you are suitable for subsidies if you receive unemployment compensation, regardless of your true full cash flow for the year, as extensive as you’re not suitable for Medicaid, Medicare, or an employer’s strategy.)

In most states, the ACA’s enlargement of Medicaid eligibility supplies protection to grown ups with family cash flow up to 138% of the poverty level, with eligibility determined dependent on existing month to month money. So if your earnings has suddenly dropped to $, you’ll probable be suitable for Medicaid and could transition to Medicaid when your job-dependent coverage finishes.

However, there are even now 11 states in which most adults experience a coverage gap if their residence profits is under the federal poverty degree. They aren’t suitable for high quality subsidies in the market (except they’ve obtained unemployment compensation in 2021 and can hence qualify for 2021 subsidies).

This is an unlucky circumstance that individuals 11 states have produced for their small-money citizens. But there are approaches for preventing the coverage gap if you’re in just one of these states.

And continue to keep in head that subsidy eligibility in the market is centered on your home profits for the full year, even if your present-day regular monthly income is under the poverty degree. So if you gained sufficient previously in the 12 months to be subsidy-eligible for 2021, you can enroll in a plan with subsidies based mostly on that income, even with the point that you may possibly not generate just about anything else for the rest of the yr.

When open enrollment begins in November, you are going to will need to undertaking your 2022 money as accurately as probable, if you’re even now needing to invest in your possess coverage for 2022. But for the rest of 2021, you can use the profits you currently gained this calendar year to qualify for subsidies.

What if I’ll soon be qualified for Medicare?

There has been an increase recently in the number of people today retiring in their late 50s or early 60s, right before they are suitable for Medicare. The ACA created this a far more sensible alternative starting in 2014, thanks to quality subsidies and the elimination of health-related underwriting.

And the ARP has boosted subsidies and manufactured them more commonly obtainable for 2021 and 2022, producing economical protection far more accessible for early retirees. That is in particular genuine for all those whose pre-retirement money could possibly have designed them ineligible for subsidies in the yr they retired, thanks to the “subsidy cliff” (which has been removed by the ARP by the close of 2022).

So if you’re getting rid of your position or selecting to leave it and you nonetheless have a several months or a several yrs ahead of you are going to be 65 and suitable for Medicare, relaxation assured that you will not have to go uninsured.

You are going to be able to signal up for a marketplace approach during your particular enrollment period triggered by the loss of your employer-sponsored approach. And even if you acquired a pretty strong cash flow in the earlier component of the calendar year, you may nevertheless qualify for premium subsidies to offset some of the price tag of your new strategy for the rest of 2021.

You are going to then be capable to update your projected revenue for 2022 all through the future open enrollment period of time your subsidies will regulate in January to replicate your 2022 income.

And market ideas are often ordered on a thirty day period-to-thirty day period basis, so you’ll be in a position to cancel your coverage when you at some point transition to Medicare, irrespective of when that comes about.

Don’t fret, get lined

The limited story on all of this? Protection is readily available, and obtaining your possess well being plan isn’t as sophisticated as it could appear to be at first glance, even if you have had employer-sponsored coverage all your lifetime.

You can indication up outside of open enrollment if you’re dropping your occupation-based mostly coverage, and there is a great probability you will qualify for monetary aid that will make your new system reasonably priced.

You can master much more about the marketplace in your point out and the accessible program selections by deciding on your point out on this map. And there are zero-cost enrollment assisters – Navigators and brokers – offered through the country to assistance you make feeling of it all.


Louise Norris is an person wellness insurance coverage broker who has been creating about health and fitness insurance plan and wellbeing reform given that 2006. She has composed dozens of viewpoints and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health trade updates are on a regular basis cited by media who go over wellness reform and by other health insurance authorities.



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The COVID SEP ended in most states. The ARP is still making premiums more affordable.


Though August 15 marked the conclude of a a person-time COVID-connected unique enrollment interval (SEP) for marketplace wellbeing insurance coverage in most states, the improved subsidies that enticed hundreds of thousands of individuals are nevertheless out there for several personal-industry prospective buyers (as mentioned underneath, the SEP is ongoing in some states).

The American Rescue Plan’s enhancements to the Affordable Treatment Act’s health coverage subsidies will go on extensive after the stop of the COVID SEP. That implies that when you do have an opportunity to buy protection once more – either by open enrollment or because of to a own qualifying existence event – you’ll possible find particular person health insurance policies substantially significantly less pricey than you could have expected.

The ARP’s affordability provisions are even now serving to with premiums

As we have noted around the previous couple of months, the American Rescue Prepare involved various provisions that make ACA-compliant strategies additional affordable than ever. The additional well being insurance plan subsidy enhancements shipped by the ARP include:

All of those people rewards go on to be readily available. The extra subsidies centered on unemployment compensation continue on by means of the end of 2021, though the other subsidy enhancements will be accessible by the stop of 2022 (and perhaps more time, if Congress extends them).

How popular are the ARP’s subsidy enhancements?

HHS reported past 7 days that extra than 2.5 million folks experienced now enrolled in protection throughout the COVID-associated particular enrollment period, and that another 2.6 million current marketplace enrollees experienced activated their ARP subsidies.

Among all of the new enrollees, ordinary following-subsidy rates ended up just $85/thirty day period, as opposed to $117/thirty day period in advance of the ARP’s subsidies turned accessible. And across all of the new and renewing enrollees, about 35% had received protection with right after-subsidy premiums of less than $10/month.

That illustrates how considerable top quality subsidies have grow to be below the ARP. And yet again, nothing at all has adjusted about those subsidies: the distinctive enrollment window has ended in most states, but the subsidies are nevertheless out there if you are eligible to enroll for the remainder of 2021 — and once more through open enrollment for 2022, which commences November 1.

So if you’re in a point out where by enrollment is nevertheless open, or if you’re eligible for an person particular enrollment interval in any point out, it’s surely in your ideal interest to see what prepare possibilities are obtainable to you.

Enrolling as soon as you are eligible will necessarily mean that you are able to start using gain of the ARP’s subsidies correct away, fairly than owning to hold out for open up enrollment and coverage that commences in 2022.

States where by enrollment proceeds

Though the COVID SEP ended on August 15 in the states that use Health care.gov – and some of the states that operate their own exchanges – enrollment is however really ongoing in many states:

Enrollment if you have a qualifying daily life occasion

Not in just one of those states? Particular enrollment durations are offered to individuals who encounter a large vary of “life modifications.” The most common set off for a individual SEP is a reduction of other coverage — ordinarily work-dependent coverage.

(Notice that there is commonly only a 60-working day window to enroll in a new prepare immediately after getting rid of other protection. But Healthcare.gov is making an exception for individuals who missing their protection as extensive in the past as January 2020, if they skipped their enrollment deadline simply because they ended up “impacted by the COVID-19 crisis.” People who want to utilize this versatility have to call the marketplace specifically to qualify for a exclusive enrollment period of time on a situation-by-circumstance foundation.)

In addition to a decline of coverage, there are also other conditions in which you are going to qualify for a SEP. They consist of situations this kind of as the delivery or adoption of a child, relationship (as extensive as at minimum just one husband or wife presently had minimum amount important protection), or even your grandmothered or grandfathered strategy coming up for renewal.

Extra prospects to enroll in ACA-compliant protection

In addition to the states with ongoing COVID-linked enrollment durations and the personal SEPs brought on by qualifying life occasions, there are other conditions underneath which you could nevertheless be eligible to enroll in inexpensive health and fitness coverage:

Mark your calendar for 2022 open up enrollment

If you do not have an enrollment interval now, be confident to mark your calendar for the start of open up enrollment on November 1. That’s when you’ll be ready to signal up for wellbeing protection that will just take influence in January, with protection for essential health and fitness benefits and pre-current situations. For the duration of open enrollment, your healthcare background won’t matter, and neither will your protection heritage.

And if you’re previously enrolled in an ACA-compliant program – or shortly will be – you’ll still want to pay out attention to open up enrollment this tumble. There are new insurers signing up for the marketplaces in many locations, which may possibly have an surprising impact on your quality subsidy. And even if you are satisfied with the program you have now, you could possibly locate that a various approach performs greater for the coming 12 months.

The good thing is, the ARP’s subsidy enhancements will go on to be offered for 2022. So if you’re suitable for subsidies – and most folks are – your protection for up coming calendar year is possible to be really cost-effective.


Louise Norris is an specific overall health insurance broker who has been crafting about overall health coverage and health and fitness reform given that 2006. She has penned dozens of views and educational parts about the Affordable Care Act for healthinsurance.org. Her point out wellness exchange updates are frequently cited by media who deal with health reform and by other overall health coverage specialists.



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How new carriers in your marketplace could affect your coverage options


Recent news about individual-market health insurance has been largely centered around the American Rescue Plan and how it’s made coverage in 2021 much more affordable than it used to be. Now, as we approach ACA’s annual open enrollment period, it’s a good time to look ahead to what we can expect to happen with 2022 coverage.

Fortunately, the ARP’s enhanced subsidies will still be in effect in 2022 – and possibly longer, if Congress can agree on an extension. That means subsidies will continue to be larger than they used to be, and more widely available, including to households earning more than 400% of the poverty level.

For 2022 individual/family coverage, we’re seeing some wide variation in proposed and finalized rate changes across the country. Average rates will decrease in some areas and increase in others, with modest single-digit rate changes in most places.

(Since the ARP has eliminated the income cap for subsidy eligibility for 2021 and 2022, few enrollees will see these rate changes reflected in their actual premiums, since most enrollees get premium subsidies. But rate changes do affect the size of the subsidy amount, and that can result in changes for after-subsidy premiums, as explained below.)

Increased insurer participation in marketplaces continues

But we’re also seeing widespread continuation of the increasing insurer participation trend that’s been ongoing since 2019. In 2017 and 2018, insurers fled the ACA’s exchanges – or even the entire individual/family market. But that started to turn around in 2019, and insurer participation increased again in 2020 and 2021.

For 2022, that trend is continuing. Some big-name insurers that previously scaled back their marketplace participation are rejoining various marketplaces, and some smaller regional insurers are joining marketplaces or expanding their existing footprints.

Where are new carriers entering ACA’s marketplace for 2022?

Here’s a summary of some of the major individual/family insurers that are entering new markets for 2022:

More carriers = more plan options …

That’s in addition to numerous coverage area expansions by existing marketplace insurers in many states. Based on the rate filings that we’ve analyzed thus far, we anticipate that many  – if not most – marketplace enrollees will have more plan options available for 2022 than they had this year.

One of the goals of the ACA was to increase competition in the individual health insurance market. The exchanges are set up to facilitate that, with enrollees able to compare options from all of the participating insurers and select the plan that best fits their needs.

From that perspective, increasing insurer participation and competition in the exchange is good. And it does give people more plans from which to choose, which can also be a good thing. But too many choices can overwhelm applicants and result in poor decision making.

… and a new carrier could also affect premium subsidies

In addition to delivering more plan options, carriers expanding into an area might also affect premium subsidies in that area. How much effect will depend on how the new plans are priced in comparison with the existing plans – keeping in mind that rates change each year on January 1 regardless of whether any new insurers are entering the market.

Premium subsidy amounts are based on the cost of the benchmark plan in each area. But since that just refers to the second-lowest-cost Silver plan, it’s not necessarily the same plan from one year to the next. If a new insurer enters the market with low-priced plans, the insurer may undercut the current benchmark and take over the second-lowest-cost spot. If the premium is lower than the benchmark plan’s price would otherwise have been, the result is smaller premium subsidies for everyone in that area.

For people in that area who prefer to keep their existing plan (as opposed to switching to the new lower-cost options), this can result in an increase in after-subsidy premiums, since the subsidies are smaller than they would otherwise have been. We can see an example of this in the Phoenix area in 2019 and 2020, when new insurers entered the market with lower-priced plans that reduced the size of premium subsidies in the area.

To clarify, anything that reduces the cost of the benchmark premium will result in smaller subsidies. This can be a new lower-cost insurer entering the market, or existing insurers reducing their rates. An example of this can be seen in how after-subsidy premiums increased for many of Colorado’s exchange enrollees in 2020, when the state’s new reinsurance program reduced average pre-subsidy premiums by about 20%. The reduction helped unsubsidized enrollees (mostly those with incomes over the limit for subsidy eligibility, which has been removed at least through 2022) but resulted in higher net premiums for many enrollees who qualified for subsidies.

Although the vast majority of exchange enrollees do qualify for premium subsidies (especially now that the American Rescue Plan has eliminated the “subsidy cliff” for 2021 and 2022) some enrollees do not. For these enrollees, the introduction of a new insurer simply broadens their plan options, and does not affect their premiums unless they choose to switch to the new plan.

And of course, if the new insurer has plans that are priced higher than the existing benchmark plan, the carrier’s entry will not affect net premiums paid by subsidized enrollees.

Plan to compare your coverage options during open enrollment

It will be several weeks before all the details are clear in terms of rate changes and plan availability for 2022 coverage. But it appears that the trend of increasing competition in the exchanges will continue.

And although the American Rescue Plan’s enhanced subsidy structure will still be in place in 2022 – making subsidies larger and more widely available than they would otherwise have been – it’s still possible for a new insurer to disrupt the market and end up adjusting the size of premium subsidies in a given area.

Open enrollment for 2022 coverage will begin November 1. Actively comparing your options during open enrollment is always the best approach, and that’s especially true if a new insurer will be offering plans in your area. Letting your current plan auto-renew without comparison shopping is never in your best interest.

If a new insurer is joining the marketplace, you may find that its plans are a perfect fit for your needs. Or you might find that your best option is to switch to a different plan because your after-subsidy premiums are increasing due to the new insurer undercutting the price of the current benchmark plan. Switching plans might be a non-starter due to your provider network or drug formulary needs, but you won’t know for sure until you consider the various options that are available to you.

Ask a professional how a new carrier could impact your coverage

We have an overview of factors to keep in mind when you’re choosing a health plan, but it’s also worthwhile to seek out professional advice. Enrollment assistance is available from brokers, enrollment counselors, and Navigators.

Brokers are licensed and regulated by state insurance departments, and must also have certification from the exchange in order to help people enroll in health plans offered through the exchange. Training and testing are necessary in order to obtain the license and certification, and brokers must also complete ongoing continuing education in order to maintain their credentials.

Broker training encompasses a wide range of topics, including ethics, fraud prevention, evolving insurance laws and regulations, and health plan details. The training and regulatory oversight make brokers a reliable source of information and assistance with initial plan selections and enrollments as well as future issues that might arise as the health plan is utilized.

Navigators should be much more widely available this fall, as the Biden administration has allocated $80 million for this year’s Navigator grants in the states that use HealthCare.gov. (The previous high was $63 million in 2016; the Trump administration subsequently reduced it to $36 million in 2017 and to $10 million each year from 2018 through 2020.) The Biden administration has also proposed a return to expanded duties for Navigators, which would provide consumers with increased access to post-enrollment assistance with their coverage.

In short, enrollment assistance should be widely available this fall, and it’s in your best interest to use it. A recent report from Young Invincibles highlights the myriad ways that enrollment assisters help consumers – it’s more than just picking a plan.

Regardless of where you seek assistance, it won’t cost you anything – and a broker, Navigator, or enrollment counselor will be able to help you determine the impact of any new insurers that will be offering plans in your area for 2022, and help you make sense of the options available to you.


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.



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Six strategies for avoiding the Affordable Care Act’s coverage gap


In eleven of the twelve states that have so far refused to enact the Affordable Care Act’s expansion of Medicaid eligibility (which the Supreme Court made optional for states in 2012), there’s good news and bad news for people who are seeking health insurance for 2022 and don’t earn a lot of income.

The good news is that COVID-19 relief legislation signed by President Biden in March of this year, the American Rescue Plan Act, vastly improved subsidies in the ACA private plan marketplace. Comprehensive coverage – a Silver plan with strong cost-sharing reductions –  is now free to many low-income Americans, and heavily subsidized for people who earn a bit more.

The bad news is that in states that have refused to enact the Medicaid expansion, the government still offers no help to people who report household incomes below the poverty line.

ACA’s coverage gap

The ACA’s creators intended for people in this income category to get Medicaid, but governors and legislators in the twelve “nonexpansion” states said no – even though the federal government foots 90% of the cost. More than 2 million low-income adults in these states are in the ACA’s coverage gap – eligible neither for Medicaid nor for help paying for coverage in the ACA private plan marketplace.

The remaining non-expansion states (excluding Wisconsin, which has no coverage gap,* and Missouri, where expansion is imminent) are as follows:

The minimum income to qualify for subsidized marketplace coverage in “nonexpansion” states is 100% of the federal poverty level (FPL). For enrollment in 2022, the cutoffs are as follows. (They are slightly lower for those still seeking coverage for the remainder of 2021.)

Persons in
family/household
100% FPL
(minimum to qualify for coverage)
1 $12,880
2 $17,420
3  $21,960
4  $26,500

A Silver plan with strong cost-sharing reduction is free to enrollees with incomes between 100% FPL and 150% FPL. (In 2022, that’s $19,230 for an individual, $39,750 for a family of four.) At 150-200% FPL, Silver coverage costs no more than 2% of income.

At incomes above 200% FPL, the percentage of income required for a benchmark Silver plan rises with income to a maximum of 8.5% of income.  But again, in non-expansion states, subsidies are not available to people in households with incomes below 100% FPL.

Stumbling blind into the coverage gap

The application for coverage on HealthCare.gov – the federal marketplace for health coverage used by all of the non-expansion states (and 24 other states) – does not highlight the minimum income required for coverage. As a result, many low-income applicants who might expect to get federal aid find themselves confronted with a choice of plans quoted at full, unsubsidized cost – an average of $452 per month per adult for benchmark Silver coverage, unaffordable for almost all low-income enrollees.

A 2015 change delivered a special enrollment period to people in 18 states whose income increased, making them eligible for subsidies.

Leaving the coverage gap? This SEP’s for you.

Very few low-income enrollees know about the minimum income requirement, or know that their state legislatures and governors have denied them the Medicaid coverage that the ACA’s creators intended for them.

Many who work uncertain hours, or are self-employed, or do seasonal work, may not recognize how many variables go into their estimate of annual household income, which determines the size of subsidy – or whether a subsidy is available at all.

For applicants with incomes near the federal poverty line, knowing the stakes – that good coverage is free just above the 100% FPL threshold, and unaffordable just below that threshold – can make the difference between coverage and no coverage. For anyone not on a fixed salary, a good-faith estimate of next year’s income allows for some wiggle room. Many applicants may miss including allowable income sources, or fail to take fluctuations in their income into account, or otherwise miss the opportunity to claim a qualifying income.

A budget resolution introduced last week by Sen. Bernie Sanders proposes to create a new federal program that would offer insurance to people in this “coverage gap.” But with Democrats holding narrow majorities in both houses of Congress, their ability to create such a program is at best uncertain. Even if they do, it likely won’t go into effect in 2022.

Open enrollment for 2022 in non-expansion states begins on November 1 and HHS has proposed an end date of January 15. For those still seeking coverage in 2021, an emergency special enrollment period open to all who lack coverage ends soon – on August 15. After that date, you need a qualifying “life change” to get coverage for the remainder of 2021.

Six tactics for avoiding the coverage gap

Here is a checklist of strategies that may help you achieve eligibility for subsidized ACA coverage.

1. Know the eligibility cutoff.  As noted above, to qualify for subsidized coverage, an applicant must estimate an annual income for the coming year that’s above 100% of the Federal Poverty Level ($12,880 for an individual, $17,420 for a couple, etc. in 2022. See the list above.) This point can’t be emphasized enough, according to Shelli Quenga, Director of Programs at the Palmetto Project, a nonprofit health insurance brokerage in South Carolina.  “You need to know what amount you’re shooting for,” Quenga says. “You need to know where that line is. HealthCare.gov does not tell you.”

Jennifer Chumbley Hogue, CEO of KG Health Insurance in Murphy Texas, is equally emphatic on this point. “If somebody calls me and they’re on the bubble, I tell them: ‘the state of Texas did not expand Medicaid. That means, if you cannot project $13,000 of income, you do not get any help. So let me ask you: Do you think you’re going to make $13,000 in 2021?’”

2. Use gross income, not net.  Many applicants don’t recognize these terms, which denote income before and after taxes. Gross income, which the application requires, is basically the largest number on the pay stub or tax form.

3. Consider earning more income if necessary.  When clients’ estimates fall short, Quenga will ask them what they can do to hit the target. “I’ll say, ‘Can you think of something you can do that’s going to earn you another $150 a month? Bake cakes? Clean houses? Mow grass? Do some babysitting? Provide some care to a nearby elderly person?’” Extra income of this sort can be entered on the application as self-employment, with wage income entered elsewhere.

4. Recognize uncertainty. The marketplace application for coverage provides a box to check “if you think your income will be difficult to predict.” That’s the case for many people – especially at low wages. If it’s hard to forecast how many hours you’ll work per week, how much you’ll make per hour (tips or overtime may make this variable), or how much work you’ll get if you’re self-employed, keep the eligibility threshold in mind as you estimate these factors.

5. Count everyone’s income. Household income includes income earned by everyone included in your tax return, including those who are not seeking coverage. Hogue cites the case of a woman in her early 60s whose husband is on Medicare and Social Security. “If your spouse is getting Social Security income, don’t forget to include it,” she says. That also holds for pensions, retirement accounts, and alimony (if awarded before 2019).

6. Consider how to count. The application allows you to estimate income on an hourly, weekly, twice-monthly, monthly or annual basis – and, if your income changes during the year, it invites you to estimate a different income for next year than for the current year. This flexibility allows you to take account of factors described below.

You can view the application on the HealthCare.gov site here. The income questions are on page 3. Note that the form recognizes the uncertainty involved in forecasting future income.

Considerations for individuals earning an hourly wage

If your income estimate is based on an hourly wage, consider the following questions:

  • Is the amount you and other workers in your household earned in the current month (or on the pay stubs you’re looking at) representative of what you are likely to earn throughout the year?
  • If you or a household member are a seasonal worker, have you fully accounted for that person’s likely full-year income?
  • Do you work more hours or earn more tips during the holiday season (or at other times of the year?) Have you fully accounted for that? Does anyone in the household take on a second job or temp job during the holiday season (or other season)? Have you included that income?
  • Do you sometimes get paid overtime?  Do the pay stubs you’re using to estimate income reflect that?
  • Do you have reason to anticipate a raise in the coming year? (For example, Florida will raise the state minimum wage to $10 per hour in September 2021, and to $11 per hour in September 2022).  If so, estimate your income on the basis of future pay rates.

Many who report income on an hourly wage basis work uneven and uncertain schedules. If a single person is unsure how many hours per week they’re likely to work, “I often tell them to put down 30 hours,” says Hogue – an amount that generally will qualify a solo applicant for coverage at an hourly wage of $8.50 or higher.

Strategies for the self-employed

Many of the low-income clients served by the Palmetto Project are self-employed, Quenga says. “Charleston is a huge destination wedding site. We have a lot of wedding planners, DJs, photographers, videographers.” Estimating next-year income is especially difficult if you’re self-employed, Quenga notes.

And for the self-employed, “Your projected income is your best guess of what you hope to earn.”  She notes that the self-employed are generally oriented toward minimizing their income for tax purposes. For the health insurance application, they have to reverse that mindset.

Considerations when estimating your income for 2022

When you apply for coverage for 2022 (or the remainder of 2021), you may have your 2020 tax return to refer to, as well as well  as pay stubs for at least 10 months’ income in 2021.  If the totals for 2020 or 2021 are below the eligibility cutoff, that’s not necessarily going to be true in the year following. When estimating income in this case, consider these questions:

Were your hours cut because of the pandemic? Regardless, can you realistically expect to work more hours in 2022 (or the remainder of 2021)? These questions apply to everyone in your household – that is, all who file taxes together and earn any income. If so, you can estimate a higher income for the coming year in good faith.

Should you check off allowable tax deductions?  The health insurance application asks about tax deductions that, if taken, reduce your gross income. The application points out that reporting these deductions “could make the cost of health coverage a little lower.” That’s true – if your income is above 150% FPL (Coverage is free up to that threshold.)

But if your income hovers near 100% FPL, these deductions could put your income below that threshold and disqualify you from subsidized coverage.  The deductions listed on the application are those taken for interest paid on student loans,  tuition and fees, retirement plan contributions, and alimony paid. If your income is near the cutoff, “do not check off a deduction that will put you under 100% FPL,” says Hogue.

If you were unemployed in any part of 2021 The American Rescue Plan provides free marketplace coverage in 2021 for any applicant who received any unemployment insurance income at any point in the year. After the emergency special enrollment period (SEP) ends on August 15, you will need to apply for a personal SEP to access this benefit – and do so within 60 days of having lost employer-sponsored coverage or experienced another qualifying life event. This particular benefit is not available in 2022.

What if your income estimate turns out to be higher than what you actually earn?

Low-income applicants may worry that they will owe large sums of money if their income estimate proves inaccurate. While those who underestimate their income do have to pay back a portion of their subsidy at tax time, that is not the case for those who overestimate income (in fact, if over-estimators pay any premium at all, they will get a partial refund).

If income for the year in question ultimately proves to fall below the 100% FPL threshold, there is no clawback of subsidies granted, unless the applicant’s income estimate is made with “intentional or reckless disregard for the facts.”

Your income estimate has to be good faith. You can’t make stuff up. But within the range of the realistically probable, you have leeway. “Suppose you mow grass for a living, and there was a drought,” Quenga posits. “You can’t control that. There is no penalty if you don’t end up hitting your target.”

Who’s checking your income anyway?

The ACA exchanges do check applicants’ income estimates against data sources such as employer records. In 2019, the Trump administration implemented a rule requiring the ACA exchanges to demand income documentation from applicants who claimed an income above 100% FPL if “trusted data sources” indicated an income below the threshold. If the enrollee failed to provide the documentation, the federal subsidy would be cut off, and the enrollee would likely lose coverage due to the unaffordability of the unsubsidized premiums.

But that rule was challenged in court, and in March 2021 a federal court ordered the Department of Health and Human Services (HHS) to rescind it. HHS responded promptly, rescinding the documentation requirement this past May. HHS did warn that its computer systems could not be retooled instantly, so that for some time, a request for income documentation would be sent in this situation. But HHS added that it would send a follow-up communication to the enrollee, saying that documentation was not required.

The ACA’s creators did not intend to shut poor Americans out of its benefits. But governors and state legislatures that refuse to enact the ACA Medicaid expansion do willfully perpetuate the coverage gap. Low-income people in non-expansion states should use every tool available to produce a good faith income estimate that will give them access to quality government-subsidized health insurance.

* * *

* States that enact the ACA Medicaid expansion offer Medicaid to all legally present adults with household incomes up to 138% FPL. Wisconsin, uniquely, offers Medicaid to adults with incomes up to 100% FPL – which is also the bottom threshold for subsidy eligibility in the private plan marketplace. No one, therefore, is excluded from aid on the basis of income.


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 ProspectHealth AffairsThe 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.



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Longer enrollment tops list of proposed marketplace improvements


EDIT, September 17, 2021: CMS has finalized the 2022 rules, mostly as proposed. (See the final rule, and a summary fact sheet.)

  • The extra month of open enrollment has been finalized, although CMS has added flexibility for state-run exchanges. They can choose to extend open enrollment as well, but they also have the option to use any deadline as long as it’s not earlier than December 15. Most of the state-run exchanges tend to extend their open enrollment windows, although there are a few that normally opt end open enrollment prior to mid-January.
  • The year-round open enrollment period for households earning up to 150% of the poverty level has been finalized. But CMS notes that this special enrollment period will only remain in effect as long as the American Rescue Plan’s subsidy enhancements are available, allowing people at this income level to obtain $0 premium benchmark plans. For now, that’s through the end of 2022, although it appears likely that Congress will extend that. 
  • CMS plans to issued guidance related to standardized health plans in the 2023 rulemaking. The proposed 2023 rules will be issued this winter, and finalized next spring. There was not time to create standardized plans for 2022, as insurers had already submitted their 2022 plan proposals last spring, and regulators have been reviewing the rates and plans all summer, in preparation for open enrollment that begins in November.
  • The separate billing requirement for abortion coverage has been repealed.
  • The relaxed guardrails for Section 1332 waivers have been repealed.
  • The Exchange Direct Enrollment option has been repealed.

Each year, HHS issues a set of rules and guidelines that apply to the health insurance exchanges created by the Affordable Care Act, and to the health plans that are sold in the individual/family market. The rule-making process includes a proposed rule, a public comment period, and then a final rule. This is normally a fairly straightforward process, but it’s been more complicated for the upcoming 2022 plan year.

The Trump administration issued the proposed 2022 rules in late November last year, and finalized some of them in January, just before inauguration day. In May, the Biden administration finalized the rest of the proposed rule changes, but noted that they intended to propose a new set of rules, with a new public comment period, in order to revisit some of the changes that had been finalized by the outgoing administration.

In late June, the Biden administration published the new proposed rules, and opened a new public comment period that continued through July 28. A total of 341 comments were submitted, and are under review by HHS.

Some of the new proposals are direct reversals of the rule changes that the Trump administration had made. Others are new ideas that are designed to help more people gain access to affordable health insurance. For various provisions, HHS notes that there are pros and cons to the proposals they’re making, and are seeking public feedback before any rules are finalized.

As is always the case, some of the proposed rules are more “behind the scenes” and wouldn’t be particularly noticeable to consumers. But there are some that would directly affect consumers, mostly by making it easier to enroll in health coverage.

How about an extra month of open enrollment?

For the last several years, the standard open enrollment period has been set at November 1 – December 15. This is the schedule that’s used by HealthCare.gov (the exchange/marketplace in 36 states), although Washington, DC and 14 states run their own exchange platforms and most of them tend to extend open enrollment.

HHS has now proposed adding an extra month to open enrollment, so that it would continue through January 15 instead of ending in mid-December. If finalized, this rule change would take effect for the upcoming open enrollment period that starts in November, for coverage effective in 2022.

HHS clarifies that the intent here is to give people more time to enroll, and give enrollment assisters more time to help everyone who needs it. They also point out that some people don’t realize how much their premiums might change from one year to the next, and are caught off guard when they get their invoice in January. By that point, however, it’s normally too late to change plans, and people might end up dropping their coverage altogether if it’s become too expensive. By giving people until January 15 to enroll, there’s time for a “do-over” if a policy was allowed to auto-renew and then ended up being more expensive than expected.

On the other hand, HHS notes that when enrollment ends in mid-December, everyone has full-year coverage, with policies that take effect in January. If enrollment is extended until mid-January, some enrollees will have coverage that takes effect in February instead. Most of the state-run exchanges already offer this, but it would take additional outreach and communication to ensure that consumers are aware that they would still need to enroll by mid-December in order to have coverage in effect as of January 1.

Year-round enrollment for people with income up to 150% FPL

HHS has proposed an ongoing enrollment opportunity for applicants with household income that doesn’t exceed 150% of the federal poverty level. If finalized, this would allow eligible applicants to enroll in coverage at any time of the year. (Under current rules, enrollment outside of the normal open enrollment period requires a special enrollment period, triggered by a qualifying life event).

This enrollment opportunity would be offered through the federally run exchange (HealthCare.gov), and state-run exchanges would have the option to offer it. HHS has clarified that it’s uncertain whether this could be added as an option for the 2022 plan year. It might need to be delayed until 2023 to give health plan actuaries adequate time to prepare for this change.

The American Rescue Plan, enacted earlier this year, has enhanced the ACA’s premium tax credits (premium subsidies) for 2021 and 2022, providing more financial help for people who buy their own health insurance. As a result, households with income up to 150% of the federal poverty level are eligible for subsidies that fully cover the cost of the benchmark plan.

That means they can select either of the two lowest-cost Silver plans and have no monthly premium. (They will also tend to have access to a variety of premium-free Bronze plans, and possibly some premium-free Gold plans. But Silver plans are generally the best option for people in this income range, due to the robust cost-sharing reductions that come with Silver plans.)

HHS notes that the enhanced premium subsidies would help to prevent adverse selection, since most applicants with household income up to 150% of FPL would be able to enroll in Silver plans — with strong cost-sharing reductions — without premiums. This means that they would be unlikely to drop their coverage after receiving medical care, as they would not have to pay anything to keep the coverage in force. (This would be applicable for 2022, assuming the year-round enrollment option could be added for 2022. For 2023 and future years, the availability of zero-premium Silver plans will depend on whether Congress extends the American Rescue Plan’s subsidy enhancements.)

However, HHS does note that some enrollees with income up to 150% of FPL do have to pay at least minimal premiums for the benchmark plan. This includes people in states where additional services beyond essential health benefits are required to be covered (and thus the premium subsidy doesn’t cover the entire cost of the benchmark plan) as well as applicants who are subject to a tobacco surcharge.

And it’s also possible for a person earning up to 150% of FPL to purchase a Silver plan that’s more expensive than the benchmark plan, and thus have a monthly premium even after the subsidy is applied.

It’s possible that there could be some adverse selection among these populations, with enrollees potentially dropping their coverage or shifting to a lower-cost plan after their medical needs are resolved. HHS is seeking public comments about how to best approach this.

It’s worth noting that Medicaid and CHIP enrollment is already available year-round, as is Basic Health Program enrollment in the two states where it’s available. In most states, Medicaid is available to adults under age 65 with household income up to 138% of the poverty level. The income caps are higher for children to qualify for Medicaid, and CHIP is available to children (and in some cases, pregnant women) in many middle-class households.

So a family with low or modest income can obtain coverage year-round in most states — for the children, and possibly the adults. This is true even though many CHIP programs — and some Medicaid programs — charge premiums. Extending open enrollment to run year-round for subsidy-eligible applicants with household income up to 150% of the poverty level would essentially just be an expansion of the enrollment eligibility rules that already exist for lower-income households.

Including the ACA’s expansion of Medicaid, health insurance exchanges, and Basic Health Programs, ACA enrollment now encompasses about 10% of all Americans. But there are still millions of Americans — most of whom have fairly low incomes — who are uninsured and possibly unaware of the financial assistance that’s available to them. HHS is working to make coverage as accessible as possible to this population, and the proposed year-round enrollment window is part of that approach.

Standardized plans return to HealthCare.gov for 2023

Five years ago, HealthCare.gov debuted standardized health plans, dubbed “Simple Choice” plans. The idea was to make it easier for consumers to compare apples to apples when looking at multiple health insurance policy options.

The Trump administration finalized a rule change in 2018 that eliminated Simple Choice plans starting with the 2019 plan year. So HHS did not create standardized plan designs for the last few years.

The 2018 rule change that eliminated standardized plan designs on HealthCare.gov was vacated by a court ruling earlier this year, as were three other provisions of the 2018 rule. So HHS is starting the process of once again creating standardized plans and gathering public feedback on how to best proceed.

And earlier this month, President Biden issued a wide-ranging executive order aimed at promoting competition in the U.S. economy. One of its provisions calls for HHS to “implement standardized options in the national Health Insurance Marketplace and any other appropriate mechanisms to improve competition and consumer choice.”

When standardized plans were previously available in the federally run exchange, it was optional for insurers to offer them and insurers were also free to offer a variety of non-standardized plans. The specifics of their reintroduction are unclear at this point, but the proposed rules seem to indicate that the plans, which are expected to be available for the 2023 plan year, will continue to be optional for insurers.

Consumer protection rules

Some of the other proposed rule changes are designed to protect consumers, although their implementation might not be obvious.

Over the last few years, HHS had implemented several regulatory changes that would have eroded various consumer protections or created confusion in the marketplace. But these rules have either been blocked by the courts or had little in the way of interest from states. And now HHS has proposed a reversal of some of them:

  • Insurers are required to collect at least $1/month in premiums to cover the cost of non-Hyde abortion coverage if it’s offered by a health plan. Premium subsidies can’t cover this amount, and insurers must keep the funds segregated from the rest of the premiums they collect. But a previous rule change required insurers to actually send separate invoices for this amount. A judge blocked that rule last year before it took effect, noting that it would lead to widespread consumer confusion. And now HHS is proposing that the rule simply be eliminated altogether. Insurers would still have to segregate the premiums for abortion services, and they still cannot be covered by premium subsidies. But no separate invoice would be required.
  • The consumer protection guardrails for 1332 waivers were significantly relaxed in 2018. Few states had expressed interest in utilizing the new rules (the vast majority of 1332 waiver proposals have continued to be for reinsurance programs), but HHS is now proposing that the more stringent 1332 waiver guardrails be restored.
  • In January, the outgoing Trump administration finalized a program known as “Exchange Direct Enrollment,” designed to allow states to abandon their ACA-created exchanges altogether and rely instead on broker and insurer websites. (Note that this is not the same thing as enhanced direct enrollment, which continues to be an option utilized by dozens of enrollment entities.) HHS has now proposed eliminating the Exchange Direct Enrollment option. The public feedback on the Exchange Direct Enrollment program was almost entirely negative, and no states had expressed an interest in pursuing this idea. (Georgia had already received approval for a 1332 waiver utilizing this concept. That approval is now under review by the Biden administration.)

The final version of the new rules is expected to be published within the next several weeks. We won’t know the status of these proposed rule changes until then, but the proposed changes we’ve discussed here are fairly likely to be finalized, albeit with possible modifications based on public comments that HHS received.


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.



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