COVID-19 Relief Bill / American Rescue Plan Act (ARPA) - Healthy MKE
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COVID-19 Relief Bill / American Rescue Plan Act (ARPA)
Private health insurance components include:
Increases Advance Premium Tax Credits (APTCs) across income levels for
2021 and 2022
Eliminates Marketplace premiums for households up to 150% FPL
Provides APTCs above 400% FPL for 2021 and 2022
Expands financial help available to people receiving unemployment
Provides free COBRA coverage through September 2021
Provides health coverage-related tax relief for 2020 tax yearCOVID-19 Relief Bill / American Rescue Plan Act (ARPA)
Marketplace implementation timeline:
Healthcare.gov updated with increased income-related subsidies April 1
Updates for people receiving unemployment slated for this summer
Reminder: 2021 special enrollment period runs through May 15*
*There has been speculation that the current 2021 special enrollment
period may be extended beyond May 15.COVID-19 Relief Bill / American Rescue Plan Act (ARPA) New Medicaid state options include: Lengthening Medicaid coverage for pregnant women Coverage for COVID vaccine and treatment Additional funding for home-and-community-based services Additional funding for states who choose to expand Medicaid Additional funding for Indian Health Services
COVID-Relief/Current Consumers
Current Marketplace
ConsumersIncreases APTCs across income levels for 2021 and 2022
Premiums reduced for all income levels and capped at 8.5% of FPL
Household Income Current Law American Rescue Plan Act
(% of the FPL)
100 – 138% 2.07% 0%
138% - 150% 3.1% - 4.14% 0%
150% - 200% 4.14% - 6.52% 0% - 2.0%
200% - 250% 6.52% - 8.33% 2.0% - 4.0%
250% - 300% 8.33% - 9.83% 4.0% - 6.0%
300% - 400% 9.83% 6.0% 8.5%
400% + N/A 8.5%
Adapted from: Impact of Key Provisions of the House COVID-19 Relief Proposal on Premiums (KFF). See also: Health Insurance Marketplace Calculator (KFF)Eliminates premiums for households up to 150% FPL
Consumers under 150% FPL will now have $0 premium
contribution requirement
All non-smoking* consumers under 150% FPL will be
eligible for a $0 benchmark (silver) plan with cost-
sharing reductions (CSRs)
*Plans can still charge a tobacco surcharge that would still applyProvides APTCs above 400% FPL for 2021 and 2022
Limits required premium contribution to 8.5% for people with
incomes above 400% FPL
A household would not receive a subsidy if the cost of the benchmark plan
is less than 8.5% of their income
Especially impactful for older adults and people who live in areas
of the state with higher premiums todayARPA: No Automatic Additional Tax Credits
If a consumer is already enrolled in a Marketplace plan, will they
receive the additional tax credits (lower premiums) automatically?
No. If consumers don’t take any action, they’ll receive the additional
benefit when they file their taxes next year. Beginning April 1, consumers
update their Healthcare.gov application and reselect their current plan
to receive the tax credits this year.
CMS is exploring whether they can internally update tax credits for 2021
plans.ARPA: Consumers Should Update Healthcare.gov Account
If a consumer is already enrolled in a Marketplace plan, should they
return to the Marketplace to review new plans?
Yes. Starting April 1, all enrollees should log in to healthcare.gov or call
the Marketplace to update their application and review plan options
before May 15.
They may find plans with lower premiums or lower out-of-pocket costs
for the same price or less than they are currently paying.ARPA: Date for Plan Changes
When will these new plan changes take effect?
May 1. A consumer who updates their application in April should see the
changes take effect starting May 1. (Based on the existing rules)COVID-Relief/ARPA: Changing Plans
Will the out-of-pocket costs a consumer has already paid for 2021 carry
over towards the deductible/OOP max of a new plan?
It depends. A consumer switching health plans should expect to start
paying toward new deductibles and new out-of-pocket maximums. If a
consumer stays with the same insurer, they should talk to the company
to see if they can carry over their previous payments.
Talk to your insurer.COVID-Relief/ARPA: Unemployment
UnemploymentExpands financial help for people receiving unemployment
Anyone receiving unemployment at any point in 2021
will have their income capped at 133% FPL for purposes
of determining Marketplace financial help
All non-smoking* consumers receiving unemployment
will be eligible for a $0 benchmark (silver) plan with
cost-sharing reductions (CSRs)
Note: This change will not be implemented until summer
*Plans can still charge a tobacco surcharge that would still applyARPA: Marketplace or BadgerCare Plus if Unemployed
Should consumers in Wisconsin receiving unemployment benefits but
with household income below 100% FPL apply for BadgerCare or
Marketplace coverage?
BadgerCare. Children and pregnant women below 300% FPL, and adults
19-64 under 100% are eligible for BadgerCare. Wisconsin won’t remove
them for exceeding these limits during public health emergency. They
should stay on BadgerCare.
People not already enrolled in BadgerCare who have income over 100%,
should go to the Marketplace.COVID-Relief/ARPA: Unemployment and Marketplace
Should consumers who are receiving unemployment benefits wait to
apply for or update their Marketplace account until changes are
implemented?
No. CMS advises people receiving unemployment to go ahead and apply,
update, or change their plan. Once the unemployment updates are
available later this summer, consumers can come back in to update their
Marketplace application. Or, they will receive money back when filing
taxes next year.COVID-Relief/COBRA
COBRAProvides free COBRA coverage through September 2021
Subsidize entire COBRA premium until September 2021 for
laid-off workers (via tax credit to employers/plans)
Extends enrollment window to allow any employee still
within their COBRA eligibility period (usually 18-36 months)
to enroll
Employers are required to notify employees within 60 days of
April 1
People who voluntarily leave work or are eligible for
Medicare or other group coverage are not eligibleShould Consumers Take COBRA Coverage?
There are some key points people should know about the
COBRA elements of ARPA:
The enrollment window is extended, but the end date is
not. COBRA typically lasts for up to 18 months after an
employee is first eligible. If an employee was eligible for
COBRA in February 2020, they can get it subsidized from
April – September, 2021, but the 18 months will end in
August.
Nothing says COBRA premiums before April 1, 2021 will
be subsidized.Should Consumers Take COBRA Coverage? (continued)
Remember: Consumers who receive unemployment
benefits in 2021 will have their income for Marketplace
premiums capped at 133% FPL
Guaranteeing $0 coverage with substantial cost-
sharing reductions.
The resulting plan options, especially at the Silver
level, could have benefits exceeding their original
health insurance.COVID-Relief/ARPA: COBRA
Will people who choose to enroll in free COBRA be eligible for a
Marketplace special enrollment period after the subsidy ends?
Yes. When a COBRA premium has a significant increase, such as when an
employer stops contributing or it stops being subsidized, a consumer can
get a special enrollment period for the Marketplace.COVID-Relief/ARPA: Tax Filing
Tax FilingProvides Health Coverage-related Tax Relief for 2020 tax year
When filing taxes this year (for 2020 tax year),
consumers will not be required to repay any excess APTC
Consumers will still get money back if their APTC was too low
First $10,200 of unemployment can be deducted (if
income below $150,000), which could mean money
back if consumers would have received a higher APTC
without that incomeCOVID-Relief/ARPA: Tax Filing
What if a consumer already filed their taxes for 2020? Can they get
money back?
Yes. The Internal Revenue Service (IRS) will need to determine how to
retroactively apply these changes for consumers who already filed their
2020 taxes. As of March 12, 2021, the IRS published a statement that
they are looking at the provisions and urging taxpayers to not file
amended returns until they have issued more guidance.COVID-Relief/ARPA: Other Considerations
Other ConsiderationsARPA: Affordable Coverage
Will ARPA help consumers who failed to sign up for affordable
employer-sponsored coverage?
It depends. With the 9.83% maximum premium contribution decreasing
to 8.5%, it stands to reason that the affordability test for employer-
sponsored coverage, which uses the same number, will also decrease.
Some large employers offer plans that are between 9 and 9.5% of
employee income, disqualifying them from Marketplace coverage. If this
is lowered, many consumers who didn’t sign up could get APTCs in the
Marketplace, especially if they act before May 15.Looking Ahead
Healthcare.gov will be updated April 1
The May 15 deadline for the new special enrollment period
could be extended, BUT assuming it is not, consumers
should act by then for most options
Consumers reporting changes after May 15, should still see
extra APTCs
Unemployment provisions will take effect in the summer.
COBRA subsidies end September 30, 2021; for some people
they will run out of COBRA before that.You can also read
