What’s New for 2022 Marketplace Enrollment?

Open Enrollment is just around the corner. There are new policies for the marketplace in 2022, including an expansion of opportunities to sign up for health coverage during and outside the annual open enrollment period. There are also new opportunities to get financial help with enactment of the American Rescue Plan (ARP) Act. Here is a summary of some changes that may affect people enrolling in marketplace plans:

  • Enhanced Premium Tax Credit Subsidies: Under the ARP, consumers who enroll in a marketplace plan are eligible for enhanced premium tax credits (PTCs) for coverage through December 31, 2022. It’s estimated four out of five federal marketplace enrollees will be able to find a plan for $10 or less per month. Under the enhanced premium credits, families with incomes between 100 and 150 percent of the federal poverty level could have their premium contribution reduced to $0. Families with incomes over 400 of the federal poverty level would have their premium contribution capped at 8.5 percent of their household income.
  • Extra Help for Unemployed Individuals: In 2021 only, the ARP provided additional marketplace subsidies for unemployed individuals. While the benefit is not available in 2022, marketplace enrollees who received, or were approved to receive, unemployment insurance (UI) benefits for at least one week in 2021 (including enrollees with income below the poverty line who lived in a state that hasn’t expanded Medicaid) are entitled to these extra tax credits for the months they were enrolled in a marketplace plan in 2021. Those who did not have the extra subsidies applied to their marketplace premium can claim the credit when they file taxes for 2021 by reconciling any PTCs they’ve received with what they should have received for the year under this ARP provision, but they will have to report their eligibility for or receipt of UI for at least one week in 2021.
  • Extended Open Enrollment PeriodOpen enrollment for 2022 coverage will last from November 1, 2021 through January 15, 2022 – one month longer than last year’s open enrollment period (OEP). State-based marketplaces (SBMs) may have a shorter OEP, as long as it ends no sooner than December 15th, and they may extend their OEPs past January 15th.
  • New Special Enrollment Opportunities:
    • Individuals and families with household income under 150 percent of the poverty line are eligible for a monthly SEP if their premiums would be $0 after applying tax credits. This will be the case in 2022, when the ARP enhanced tax credits reduce premiums to $0 for those in this income group. This SEP is only available through the marketplaces. SBMs can choose whether or not to make this low-income SEP available.
    • Individuals with COBRA continuation coverage may qualify for a SEP to enroll in coverage on- or off-marketplace when they lose employer contributions or government-funded COBRA subsidies for continued employer health coverage.
    • Individuals who lose eligibility for PTCs and are eligible for a SEP can enroll in a new plan at any metal level, making it possible to change to a lower cost plan.
    • Individuals who did not receive timely notice of a triggering event for a SEP may qualify for a SEP to enroll in a marketplace plan within 60 days of learning of the triggering event.
  • Failure to Reconcile Tax Credits: Under regular rules, individuals who fail to file taxes and reconcile the PTCs they received in the previous year with the amount they should have received may lose their PTCs when they are automatically reenrolled in a marketplace plan. However, federal guidance granting flexibility to taxpayers in response to COVID-19 says individuals will not lose their advanced PTCs for 2022 coverage for failure to reconcile their PTCs, nor will taxpayers be required to pay back any excess PTCs (when PTCs received in a tax year are greater than what the individual was eligible to receive.
  • Expanded Navigator Responsibilities: Navigators are required to help consumers with post-enrollment services, including how to use their coverage, updating applications, and filing appeals of exchange eligibility determinations. Although many continued to do this even after previous federal rules repealed this requirement, it is once again a required part of Navigator duties in states with a federally facilitated marketplace.
  • Cost-Free Coverage of Pre-exposure prophylaxis (PrEP): The U.S. Preventive Services Task Force (USPSTF) gave PrEP, a once-daily pill used to prevent HIV transmission, a Grade A recommendation, making coverage of PrEP a preventive service that must be available without cost-sharing for plan years starting on or after June 2020. Federal guidance requires plans to cover not only the medication used for PrEP without cost sharing, but also the essential support services that are part of the intervention. These additional services include regular HIV testing, STD testing, hepatitis testing, kidney function testing, and adherence counseling. The federal guidance also clarified that because there are now multiple anti-retroviral medications available for PrEP, consumers must be able to receive the PrEP medication that is clinically indicated for them, without cost sharing.
  • New Balance Billing Protections: A federal law that takes effect in 2022 protects patients from receiving surprise medical bills. These bills can occur when individuals receive emergency care from an out-of-network facility or provider, or when an individual gets non-emergency care at an in-network facility but receives some services during their stay from an out-of-network provider. For example, an individual may schedule surgery with an in-network surgeon at an in-network hospital, but the anesthesiologist that provides services during the surgery is out-of-network. Under the No Surprises Act, the out-of-network provider cannot send a balance bill to the patient. The patient would only be responsible for in-network cost-sharing under their plan. This new protection applies to individual market plans, including marketplace plans, as well as employer-sponsored coverage.
  • Transparency Requirements: Employer plans and insurers must include information on the plan’s deductible and out-of-pocket limit on any electronic or physical insurance ID card issued to enrollees. ID cards must also include a telephone number and website address for where to get consumer assistance and further information on the plan’s cost-sharing. This new requirement applies to plans and policies that begin on or after January 1, 2022.
  • Public Charge Rule: A previous policy instituted by the Trump administration expanded the definition of a “public charge” for immigrants applying for admission to the U.S. or permanent residency (green card). That rule is no longer in effect. Enrollment in health coverage programs such as Medicaid (except for institutional long-term care) will not impact public charge determinations.
  • Two Payment Rule for Abortion Services: A previous policy instituted by the Trump administration required insurers to send two separate monthly bills, one for abortion coverage and one for coverage of all other services. That rule is no longer in effect. Consumers are able to pay their monthly premium in a single transaction.

Stay tuned for more information about marketplace enrollment in our Navigator Resource Guide, set to relaunch at the end of the month just in time for the Open Enrollment Period. The updated guide will feature hundreds of frequently asked questions, state-specific enrollment information, and the opportunity for Navigators and consumers to “Ask an Expert” complex enrollment questions.

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The opinions expressed here are solely those of the individual blog post authors and do not represent the views of Georgetown University, the Center on Health Insurance Reforms, any organization that the author is affiliated with, or the opinions of any other author who publishes on this blog.