The Centers for Medicare & Medicaid Services (CMS) has issued guidance on how Healthcare.gov and participating state exchanges will determine whether those who received an advanced premium tax credit (APTC) or cost-sharing reduction (CSR) in 2015 will still be eligible for the 2016 plan year.
As was the case for the 2015 plan year, Healthcare.gov will renew coverage for enrollees who take no action. They will not automatically enroll them in the same plan, however. Instead, CMS will use a set of metrics to project their income and determine their eligibility.
"Updating income information for growth in the [federal poverty line] and using 2016 benchmark plan premium and prior year tax return information to determine eligibility for those who do not return to the marketplace is new for 2016 and should result in more accurate eligibility determinations," Timothy Jost, a professor at the Washington and Lee University School of Law, wrote in a Health Affairs post.
Another change outlined in the CMS document centers on the Marketplace Open Enrollment Notice. In 2015, the notice went to all qualified individuals. However, for the 2016 plan year, this notice will go only to enrollees who plan to retain their coverage, CMS said.
The notice will include reminders such as the need to report eligibility changes, the enrollment deadline for coverage effective Jan. 1, 2016 (which is Dec. 15 of this year) and the final day of open enrollment (Jan. 31, 2016). The open enrollment period for the 2016 plan year begins Nov. 1.
CMS will issue a variety of special notices as well. For example, those who reported to the IRS an income change of at least 50 percent, or those with an income approaching the upper limit of APTC or CSR eligibility, will receive a notice "indicat[ing] that it may be particularly important for the enrollee to contact the Marketplace to obtain an updated eligibility determination," CMS said. Notices will also go to those who did not authorize Healthcare.gov to use tax return data to redetermine their eligibility or didn't file a tax return at all.
About 11.7 million Americans enrolled in a health insurance plan through the federal and state marketplaces this year, FierceHealthPayer previously reported. About 86 percent of them qualified for subsidized insurance.
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