Navigator Guide FAQs of the Week: Covid-19 Pandemic Concerns

Open Enrollment in most states ends on Tuesday, December 15. As consumers finish weighing their coverage options, the CHIR team is highlighting frequently asked questions (FAQs) from our recently updated Navigator Resource Guide. In this installation, we answer FAQs about insurance concerns consumers may have due to the national public health emergency caused by the novel coronavirus (COVID-19) pandemic.

My hours at work were cut back due to the COVID-19 pandemic, resulting in a temporary loss of income. Can I qualify for premium tax credits?

Possibly.

If you are already enrolled in a marketplace plan (either through HealthCare.gov or your state’s marketplace), you should report the change in income. If you previously qualified for premium tax credits, and your income loss qualifies you for additional tax credits, you will be able to adjust how much of your tax credit you apply towards each month’s premium. If you are newly eligible for premium tax credits, you should qualify for a special enrollment period and will be able to switch your health plan within the same metal level of your current health plan. If your income has fallen to between 100 and 250 percent of the federal poverty level, you can switch to a silver-level plan in order to benefit from the cost-sharing reduction subsidies to lower your copayments and deductibles.

If you are enrolled in an individual market plan outside of the marketplace and experience an income reduction that makes you newly eligible for premium tax credits, in most states you are eligible to enroll in marketplace coverage and access financial assistance. See this FAQ for more information.

If you are currently enrolled in job-based insurance and your lost hours made you ineligible for your employer’s plan, you will qualify for a special enrollment period for 60 days from the day you lost eligibility for your job-based insurance (although there may be an extension for exceptional circumstances), and depending on your income level, you might qualify for premium tax credits to subsidize your monthly premiums. You may also be eligible for your job’s COBRA benefits to extend your job-based benefits. See our FAQ on COBRA benefits to weigh the pros and cons of opting for COBRA or switching to an individual market health insurance plan.

If you are currently uninsured, your ability to qualify for a special enrollment period and/or premium tax credits will depend on the state in which you live. To find more information, see our FAQ on being uninsured during the COVID-19 pandemic. Note that for your state health insurance marketplace, your income is a projection of what you expect to make over the entire year. If your projected income is lower than the actual income you report on your 2020 tax return, you may owe back a portion or all of the premium tax credits received. You will not have to pay back cost-sharing reduction subsidies. If your current income is at or below 138 percent of the federal poverty level, you may be eligible for Medicaid, depending on the state in which you live.

I lost my job due to the COVID-19 pandemic and am now uninsured. What are my options for health insurance?

If you were previously enrolled in your employer’s group health plan, you should be eligible for a special enrollment period for 60 days from the day you lost your job-based coverage. You can go onto your state’s health insurance marketplace website and file for a special enrollment period. Some important income information applies:

If your current monthly income is below 138 percent of the federal poverty level, and you live in a Medicaid expansion state, you may qualify for Medicaid. In non-expansion states, only very low-income parents with dependent children may qualify.

If you are not eligible for Medicaid in an expansion state, and your projected annual income for 2020 is between 138 and 400 percent of the federal level, you should be eligible for premium tax credits.

If you live in a non-expansion state, and your income is between 100 and 400 percent of the federal poverty level, you should be eligible for premium tax credits. However, if your income is below 100 percent of the federal poverty level, you may be ineligible for Medicaid or premium tax credits.

Note that for your state health insurance marketplace, your income is a projection of what you expect to make over the entire year. For more information on income projections, see our federal poverty level table and our FAQ on what counts as income for HealthCare.gov.

In August of 2020, federal funds became available to supplement unemployment insurance payments. Consumers in almost every state filing for unemployment insurance due to the COVID-19 pandemic were eligible to receive an increase of $300 per week to unemployment benefits (possibly up to an additional $400 in some states) for a limited time period. While the federal government hasn’t provided clear guidance on how this will be counted for purposes of determining marketplace subsidy eligibility, federal guidance indicates the additional $300 is not included in assessments for Medicaid and CHIP eligibility (treatment of the additional $100, if available, has yet to be determined for either subsidy or Medicaid eligibility determinations).

I am uninsured and worried about the COVID-19 pandemic. Can I enroll in insurance now, or do I have to wait for the next Open Enrollment Period?

It depends. Some states have opened special enrollment periods for those who are currently uninsured amid the COVID-19 pandemic. To see if your state has opened a special enrollment period, see this state-by-state map.

Note that you may also be eligible for a special enrollment period if you meet certain criteria, like losing job-based health insurance or moving. For more information, see our FAQ on special enrollment periods.

If you are ineligible for or miss a special enrollment period, you must wait for the next Open Enrollment Period to sign up for health insurance. Note that if your income is below 138 percent of the federal poverty level, you may be eligible for Medicaid benefits depending on the state you live in. Check with your state’s marketplace or Medicaid agency to determine if you are eligible for Medicaid.

I filed my taxes but I still received a “Failure to Reconcile” notice from the IRS. What should I do?

When you receive advance premium tax credits (APTCs) through the marketplace, you are required to file an income tax return including IRS form 8962 to reconcile the APTCs that were paid on your behalf. If you don’t fulfill this requirement, you will receive what is known as a “Failure to Reconcile” notice which will warn you that you may lose your APTCs if you do not file your income tax return. Sometimes this gets mailed out to people inadvertently because of IRS data delays. If you received a failure to reconcile notice but you did file your taxes, you should log back into your marketplace application and attest to having filed your tax return. A question appears asking if you reconciled your APTCs on your tax return for the past year, and you can attest, under penalty of perjury, that you did in fact file a tax return and reconcile past APTCs for all applicable years. This will allow you to maintain eligibility for APTCs even if the IRS’ data has not been updated.

Open Enrollment runs through December 15th in most states. Look out for more weekly FAQs from our new and improved Navigator Guide, or browse our COVID-Resource Center for additional resources to stay up to date on the latest in private health insurance coverage.

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