Contributed by Rebecca Dobbs Bush
While most of us have had just about enough when it comes to discussing Health Care Reform, the discussions aren’t even close to being over. The most anticipated provisions, the individual and employer mandates, are scheduled to take effect January 1, 2014.
Many employers are focused on more of an internal analysis – evaluating whether they need to implement a group health plan or change the structure of their current benefit offerings to manage their exposure to penalties under the employer mandate provisions. At the same time, it is critical to understand the options for individuals to receive subsidies and the availability of individual plans for purchase on state/federal insurance exchanges. Along with the mandate provisions, insurance exchanges and individual subsidies also become available as of January 1, 2014. As an employer, have you determined how many in your workforce might be eligible for subsidies in the event you didn’t offer insurance or in the event your group health plan offering is not “affordable” and of “minimum value?” Not only should you be looking at this to be able to evaluate compensation and benefits offerings to employees, whether an individual is eligible for a subsidy can determine whether you have any penalty exposure for that particular individual.
Citizens and legal residents with household incomes between 100% and 400% of the federal poverty level (who purchase coverage through a health insurance exchange and do not have access to an “affordable” health plan of “minimum value” through their employer) are eligible to receive a monthly advance tax credit to reduce the cost of their coverage. The amount a person can receive is based on the premium for the second lowest cost plan available on the exchange (i.e., a silver plan) and varies based on their income.
For example, a household of 4 earning approximately $46,100 is at 200% of the federal poverty level. This family would not have to pay more than 6.3% of their income ($2,904.30) if they decide to purchase coverage on the exchange at a benchmark level of silver or lower. For the sake of example, if you assume the annual cost of family coverage in a silver plan is around $10,000, this family would receive monthly tax credits in advance totaling approximately $7,000 annually. The amount they receive in subsidies is tied to the cost of the silver plan. However, they are free to access the same amount of subsidy and use it to purchase the cheaper bronze plan.
For those between 100% to 250% of the federal poverty level, they would also be eligible for subsidies to assist with out-of-pocket costs at the point of service, such as deductibles, copayments and coinsurance. In the above example, if the family purchased a silver plan (which will have an actuarial value of 70%), they would receive additional subsidies to essentially improve the actuarial value of their coverage to 87%.
But remember, access to all of these subsidies for the family in the example above disappears where an employer offers “affordable coverage” at a “minimum value.” Based on IRS clarification, an employer’s coverage is “affordable” and of “minimum value” if the cost of covering the employee only is no more than 9.5% of that employee’s income and the actuarial value of the plan is at least 60%. The test for affordability is not based on the cost of family coverage in an employer’s health plan.
It is estimated that approximately 68% of the population is at or below 400% of the federal poverty level. Have you evaluated how many employees in your workforce might be eligible to receive a subsidy and how your anticipated benefit offerings compare? The Kaiser Family Foundation has published a subsidy calculator to use in examining the impact of the subsidy at different income levels, ages, family sizes, and regional costs. It can be found here: http://healthreform.kff.org/subsidycalculator.aspx