Question: What if a consumer files his or her tax return without Form 8962? Answer: Tax filers must file their tax return with the IRS Form 8962 to reconcile advance payments of the premium tax credit (APTC). Question: Does a consumer’s eligibility for Medicaid, in addition to actually being enrolled in Medicaid, disqualify a consumer from receiving advance payments of the premium tax credit (APTC)? Answer: Consumers who are determined eligible for or are enrolled in coverage through Medicaid or CHIP that qualifies as minimum essential coverage (MEC) are ineligible for APTC for themselves, and for income-based cost-sharing reductions (CSRs) to help pay for the cost of their Marketplace coverage. Question: Is loss of advance payments of the premium tax credit (APTC) or income-based cost-sharing reductions (CSR) a qualifying event for a special enrollment period (SEP) for consumers to change their Marketplace plan? Answer: A consumer may qualify for a Special Enrollment Period if he or she (or anyone in his or her household):
- Is enrolled in Marketplace coverage and report a change that makes him or her: Newly eligible for help paying for coverage; Ineligible for help paying for coverage; Eligible for a different amount of help paying for out-of-pocket costs, like copayments.
- Become newly eligible for Marketplace coverage because he or she has become a U.S. citizen, U.S. national, or lawfully present individual.
- Become newly eligible for Marketplace coverage after being released from incarceration (detention, jail, or prison).
- Gain or maintain status as a member of a federally recognized tribe or Alaska Native Claim Settlement Act (ANCSA) Corporation shareholders (he or she can change plans once per month).
- Become newly eligible for help paying for Marketplace coverage because he or she had a change in household income or moved to a different state and he or she was previously both of these: Ineligible for Medicaid coverage because he or she lived in a state that hasn’t expanded Medicaid; Ineligible for help paying for coverage because his or her household income was below 100% of the Federal Poverty Level (FPL).
Question: How would a consumer become enrolled in both Medicaid/Children’s Health Insurance Program (CHIP) and a Marketplace plan with advance payments of the premium tax credit (APTC) or income-based cost sharing reductions (CSR)? Answer: A consumer may experience a life change (e.g., drop in income) making him or her eligible for Medicaid or CHIP, but he or she may fail to end Marketplace coverage with APTC/CSRs after being determined eligible for Medicaid or CHIP. Similarly, consumers who are enrolled in Marketplace coverage with APTC/CSRs may apply for Medicaid or CHIP directly with the state agency and be determined eligible, but fail to end Marketplace coverage with APTC/CSRs. While the Marketplace reinforces in many places the importance of reporting changes directly to the Marketplace and ending Marketplace coverage with APTC/CSRs after being determined eligible for or enrolling in other minimum essential coverage, this notice is a reminder to these consumers who may not have been aware that they need to end their Marketplace coverage with APTC/CSRs after being determined eligible for Medicaid or CHIP. Question: Will the process for termination of advance payments of the premium tax credit (APTC) or income-based cost sharing reductions (CSR) be the same for consumers who are enrolled in Medicare? Answer: This noticing effort is the first step the Federally-facilitated Marketplace (FFM) is taking to make sure consumers take action to end their Marketplace coverage with APTC because they are receiving Minimum Essential Coverage (MEC) Medicare. The FFM does expect to turn off APTC/CSR for consumers who are found to be dually-enrolled in a Marketplace plan with financial assistance and Medicare once it is operationally feasible. Question: If consumers have recently amended their federal income tax returns, how long do they need to wait in to reapply for Marketplace coverage? Answer: The Internal Revenue Service (IRS) takes 3-10 weeks to process a tax return based on how it is filed. Consumers should update their application, or reapply for coverage, during the Open Enrollment Period which begins November 1, 2016. After tax filers have filed their tax return, they can attest on the application to having filed their taxes for all past years that they received advance payments of the premium tax credit (APTC). Consumers should update their application and select a plan by Dec 15, 2016 to have coverage effective Jan 1, 2017. Question: If a consumer received a final Medicaid/Children’s Health Insurance Program (CHIP) Periodic Data Matching (Medicaid/CHIP PDM) notice, but is not enrolled in Medicaid or CHIP, can he or she appeal the Marketplace’s decision to end advance payments of the premium tax credit (APTC) and income-based cost-sharing reductions (CSRs)? Answer: A consumer can appeal the Marketplace’s decision about his or her eligibility for health coverage, including eligibility for APTC and CSRs, within 90 days from the date of the notice. A consumer may appoint an Authorized Representative to help with his or her appeal, or may participate on his or her own. If a consumer requests an appeal, he or she may be able to maintain eligibility for coverage while the appeal is pending. Note that the outcome of an appeal could change the eligibility of other household members on the consumer’s Marketplace account, even if they do not ask for an appeal. Information regarding a consumer’s right to appeal and instructions on how to do so are included in the final notice. Question: When were failure to reconcile (FTR) notices sent to consumers? Answer: FTR warning notices were sent in May 2016 letting affected consumers and members of their households know they were at risk of losing advance payments of the premium tax credit (APTC) because Internal Revenue Service (IRS) records indicated they did not have a 2014 federal income tax return on file. Question: Does simply filing a 2014 federal income tax return automatically count as reconciling advance payments of the premium tax credit (APTC)? Answer: Tax filers must file their tax return with the Internal Revenue Service (IRS) Form 8962 to reconcile APTC.
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