Major changes to the ACA marketplace subsidies included in the American Rescue Plan Act (ARPA) went into effect yesterday, along with an increase in federal subsidies for COBRA premiums to 100 percent.

As of April 1, premium tax credits are now available to those with incomes above 400 percent of the Federal Poverty Level for 2021 and 2022, effectively eliminating the ACA’s “subsidy cliff” during that time period. Also effective April 1 is the provision of ARPA that reduces the level of income that individuals must contribute toward their premiums. For individuals who received, or are approved to receive, unemployment benefits this year, their income will be treated as no higher than 133 percent of the FPL. However, those benefits did not go live on April 1, and instead will begin in early July.

For new consumers enrolling for the first time on or after April 1, the process is the same: Complete the application, receive an eligibility determination, select a plan and pay the first month’s premium (with the option of receiving PTCs in advance). Those who enrolled prior to April 1, however, need to return to HealthCare.gov and update their application to receive new eligibility results, and decide how they want to use the additional tax credits allotted by ARPA. If a current enrollee does not claim their enhanced PTCs, those credits will be reflected in their 2022 taxes.

HHS announced this week that it will spend an additional $50 million in advertising to bolster this SEP through August 15. HHS hopes this advertising will entice uninsured consumers, gig workers who may have experienced a reduction in hours, those who have lost coverage in 2020 or 2021, and consumers who may be newly eligible for financial assistance and PTCs. As a reminder, if you work with clients in the individual market who now qualify for subsidies on the exchange, you can still complete the HealthCare.gov agent/broker registration and training for plan year 2021 in order to help consumers take advantage of the SEP to enroll in 2021 coverage on the exchange. CCIIO has this resource available to help you understand what steps you need to take to complete registration and training in the Marketplace Learning Management System.

We are still awaiting guidance from federal agencies regarding specifics surrounding ARPA’s changes to COBRA subsidies. There are still many outstanding compliance questions, as NAHU has outlined in recent webinars and podcasts. Specifically, the Treasury Department may permit an advance credit for employers, while the Department of Labor is expected to issue model COBRA notices addressing the subsidy. As always, NAHU is monitoring pertinent regulatory developments.