The American Rescue Plan Act (ARP) expanded access to affordable health insurance coverage in a variety of ways. Starting July 1, consumers who faced a job loss this year can return to their marketplace application and find themselves eligible for health plans with a $0 premium and lower out of pocket costs for the remainder of 2021. This blog post provides an overview of this new provision, the timeline of implementation, and outlines how to access these new benefits.

Who is Eligible for These Expanded Subsidies?

The ARP expanded eligibility for advance premium tax credits (APTCs) and cost sharing reductions (CSRs) on the individual marketplace to those who received or were approved to receive unemployment compensation in 2021. This group is eligible for APTCs that cover the full premium of the second lowest cost silver plan in their area and for cost sharing reductions (CSRs). In order to be eligible for these expanded subsidies, a non-dependent taxpayer has to have received or been approved to receive unemployment compensation income for any week beginning in 2021, and be otherwise eligible to receive APTCs. As long as a taxpayer meets these requirements, their 2021 income does not impact their eligibility for APTCs under this provision. Tax dependents who received unemployment compensation are not able to receive APTCs for an entire household’s coverage if they were the only household member to receive unemployment compensation. They are, however, able to gain eligibility for CSRs if they choose a silver level plan. Beyond the traditional income eligibility, all other APTC eligibility requirements remain in place. APTC applicants must be U.S. citizens or lawfully present immigrants. Additionally, consumers are not eligible if they have another offer of minimum essential coverage. This includes an offer of an affordable group health plan from an employer or spouse’s employer, Medicare, or Medicaid.

This also means that if someone is eligible for Medicaid, they are not eligible for APTCs even if they did receive unemployment compensation in 2021. One noteworthy effect of this provision is the expanded eligibility for those that fall in the “Medicaid gap.” Generally, low-income adults who live in states that have not expanded Medicaid under the Affordable Care Act are not able to access APTCs because only those with incomes above 100 percent of the federal poverty level are eligible for financial assistance. The law intended those below 100 percent to be eligible for Medicaid, but as states opted against this, it left a population of low-income adults ineligible for either form of assistance. However, this new unemployment compensation eligibility for APTCs provides access to some of those who may have previously been ineligible for APTCs. Because this provision provides eligibility regardless of household income, those adults with incomes below 100 percent of the federal poverty level are able to receive APTCs to cover the entire premium of a benchmark marketplace plan for the duration of 2021 if they meet the other requirements under this provision. This by no means fully addresses the Medicaid gap because there are many in this population who may not have received or been approved to receive unemployment compensation in 2021.

How do I Access These New Benefits?

In order to access these new benefits, consumers are encouraged to return to their marketplace application and report their unemployment compensation income. If the unemployment compensation income is not from the last month, consumers will be prompted with a new question to attest to their receipt or approval to receive unemployment compensation in 2021. If consumers do this before July 31, they will be eligible for these enhanced subsidies beginning August 1, 2021. These new subsidies are only available for 2021 plans. Eligible consumers will be able to claim retrospective premium tax credits when they file their 2021 income tax return. If consumers are eligible for these enhanced subsidies, CMS is also encouraging them to return to their marketplace applications before the Special Enrollment Period ends on August 15.

For more information, visit HealthCare.Gov and check out CHIR’s Navigator Resource Guide FAQs about this newly implemented provision of the American Rescue Plan Act.