Changes from 2015 to 2016... Rules, Premiums, Plans, Exchanges, Etc.
- Thread starter AllenChicago
- Start date
Q9: What is the impact on consumers who are enrolled in both Medicaid/CHIP and a Marketplace plan with APTC?
A9: Consumers determined eligible for Medicaid or CHIP are not eligible for a Marketplace plan with APTC or CSRs. The Marketplace sends a notice to the household contact for applications with consumers enrolled in both programs. If consumers who are determined eligible for Medicaid or CHIP and who are enrolled in a Marketplace plan with APTC or CSRs do not end their Marketplace coverage with APTC or CSRs, the tax filer(s) will likely have to pay back all or some of the APTC received for a Marketplace plan while the consumers are enrolled in both programs when taxes are filed, starting the first of the month following the Medicaid or CHIP eligibility determination. In accordance with IRS regulations, repayment is subject to statutory caps.
Does anyone know what the statutory caps are? Do they use the same caps as for situations when MAGI is higher then projected?
A9: Consumers determined eligible for Medicaid or CHIP are not eligible for a Marketplace plan with APTC or CSRs. The Marketplace sends a notice to the household contact for applications with consumers enrolled in both programs. If consumers who are determined eligible for Medicaid or CHIP and who are enrolled in a Marketplace plan with APTC or CSRs do not end their Marketplace coverage with APTC or CSRs, the tax filer(s) will likely have to pay back all or some of the APTC received for a Marketplace plan while the consumers are enrolled in both programs when taxes are filed, starting the first of the month following the Medicaid or CHIP eligibility determination. In accordance with IRS regulations, repayment is subject to statutory caps.
Does anyone know what the statutory caps are? Do they use the same caps as for situations when MAGI is higher then projected?
- Thread starter
- #153
- 8,448
Are you referring to the APTC income-based clawback caps? I don't think Medicaid folks will be expected to pay back amounts that, in some cases, exceed half their annual income.
- Thread starter
- #155
- 8,448
I'm referring to the income-based cap on APTC repayment, Somarco. We've discussed this subject several times since 2013. See this chart:
Health Reform FAQs | The Henry J. Kaiser Family Foundation
Let me give you an example:
Let's say a person had Medicaid and received $3,000 APTC in 2015. The person does his/her taxes in March 2016. MAGI on the tax return in $10,000.
Now, would the person have to pay back all or some of the $3,000 APTC?
As quoted from IRS document in my previous post "In accordance with IRS regulations, repayment is subject to statutory caps".
Are the statutory caps the same as income-based caps on APTC repayment? If yes, then the person would have to pay back only $300 (Instructions for Form 8962, Premium Tax Credit (PTC) - Part 3—Repayment of Excess Advance Payment of the Premium Tax Credit).
The question remains if they are the same caps.
Let's say a person had Medicaid and received $3,000 APTC in 2015. The person does his/her taxes in March 2016. MAGI on the tax return in $10,000.
Now, would the person have to pay back all or some of the $3,000 APTC?
As quoted from IRS document in my previous post "In accordance with IRS regulations, repayment is subject to statutory caps".
Are the statutory caps the same as income-based caps on APTC repayment? If yes, then the person would have to pay back only $300 (Instructions for Form 8962, Premium Tax Credit (PTC) - Part 3—Repayment of Excess Advance Payment of the Premium Tax Credit).
The question remains if they are the same caps.
- Thread starter
- #158
- 8,448
Pancur, based on the IRS instructions you linked to, only one statutory cap is referenced in connection with APTC repayment. An investigation into other sources describing APTC only mention one repayment cap as well. As far as I can ascertain, there are no additional IRS forms associated with APTC reconciliation calculation for individual taxpayer households. Only form 8962.
Additional Reference Document from CMS with Q&A's related to dual Medicaid / Marketplace enrollees:
https://www.cms.gov/CCIIO/Resources...ownloads/Periodic-Data-Matching-FAQ-92815.pdf
Similar threads
