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If my income is less than expected this year, I might be eligible for Medicaid. What can I do to cover my bases?

You can switch between Medicaid and a subsidized plan if your income fluctuates – as long as you're in a state that has expanded Medicaid.

Q. I’m self-employed, so my income varies from one year to the next. I enrolled through the exchange and projected an income that makes me eligible for premium subsidies, but what if my income actually ends up being low enough that I would have been eligible for Medicaid instead? Will I have to pay back those subsidies? What if I don’t take monthly subsidies and use my savings to pay premiums, hoping my income will increase? What’s the best strategy for me right now?

A. Income volatility and its impact on subsidy eligibility have been addressed by various provisions of the ACA and IRS regulations. But as of 2021, the rules have become more consumer-friendly for people who would otherwise be caught in the “coverage gap” in states that have not expanded Medicaid.

Lawsuit and new HHS guidance protect people whose income might dip below the poverty level

Starting with 2019 coverage, if an applicant in a state using the HealthCare.gov exchange attested to having an income that would have made them subsidy-eligible, and the electronic data the government already has on hand (eg, tax returns, Social Security data, etc.) indicated that the person’s income was likely below the poverty level (and thus not subsidy-eligible), the exchange would request additional documentation from the applicant to verify the attested income. (This is assuming the difference between the attested income and the government’s electronic data was more than a “reasonable threshold,” which had to be at least a 10% difference.)

If the applicant couldn’t provide documentation to support the attested income, the exchange would make a subsidy eligibility determination based on the income data that the government already had — in other words, the applicant would be found to be ineligible for premium subsidies and cost-sharing subsidies. This was detailed in the 2019 Benefit and Payment Parameters, finalized in April 2018.

But in March 2021, a court overturned four provisions that had been in the 2019 Notice of Benefit and Payment Parameters — including the rule that had required income verification when an applicant projected income above the poverty level but federal data indicated an income below the poverty level.

In May 2021, CMS published the final Notice of Benefit and Payment Parameters for 2022 (see page 24216), and clarified that they would no longer require income verification in these situations. They noted that it would take some time to integrate this new rule with the automated system, and that applicants may still get automatically-generated requests for income verification. But in that situation, they will manually notify those consumers that they can disregard the request for additional income verification documentation.

This is particularly important in the dozen states where a coverage gap exists due to the states’ failure to expand Medicaid eligibility. In those states, there is no financial help available for many applicants who project an income below the poverty level, since Medicaid isn’t available unless they’re eligible based on the state’s existing pre-ACA guidelines. But with the new rules in place, they can project an income just above the poverty level (HealthCare.gov is the exchange in all of the states where a coverage gap exists).

People whose income ends up being below 100% of the poverty level generally do not have to repay advance premium tax credits when they file their tax return. But as noted below, that only applies if the applicant provided information to the exchange in good faith, without “intentional or reckless disregard for the facts.”

Here are some additional tips to keep in mind when you’re enrolling:

Update the exchange when your circumstances change

It is essential to notify the exchange of any income fluctuations (or other changes that could impact subsidy eligibility, such as a change in family size) when circumstances change throughout the year. The exchange can recalculate your subsidy or Medicaid eligibility at that time, and make changes as necessary.

Enroll on-exchange if your income is uncertain

Enroll in Medicaid if you’re eligible. For people who aren’t eligible for Medicaid but who have uncertain incomes, it’s generally a good idea to enroll through the exchange during open enrollment. If you do, and your income ends up being in the subsidy-eligible range for the year, you can notify the exchange of your new income and start claiming premium tax credits at that point. And when you reconcile your premium tax credit on your tax return, you’ll be able to claim the tax credit for each month of the year, since you were enrolled in an exchange plan throughout the year.

Prior to 2020, there was no provision to allow people enrolled in plans outside of the exchange to switch to an on-exchange plan if their income changed mid-year and made them newly-eligible for premium tax credits, since an income change was only considered a qualifying event if the enrollee already had a plan in the exchange.

But that changed as of 2020, as off-exchange enrollees now have the option to switch to the exchange mid-year if their income changes to a subsidy-eligible level (note that this transition has been somewhat complicated, and enrollment assisters report difficulties with obtaining this special enrollment period in many states). In that case, however, the subsidies would only be available on a pro-rated basis for the months that the person ends up having on-exchange coverage, rather than for the entire year (regardless of income, subsidies cannot be used to offset premiums for plans purchased outside the exchange).

Some people who don’t qualify for premium subsidies prefer to shop outside the exchange because they want to purchase a silver plan and are able to get lower-priced silver plans outside the exchange. That continues to be true in many states, so this is a decision that enrollees have to make on a case-by-case basis.

You can switch from Medicaid to a private plan and vice versa if your income fluctuates during the year

You can switch between Medicaid and a subsidized plan if your income fluctuates, as long as you’re in a state that has expanded Medicaid. Medicaid enrollment is available year-round, and conversely, loss of Medicaid is a qualifying event that allows you to enroll in an exchange plan. Efforts have been made to minimize this “churning” in order to provide more stability for low-income insureds, but the estimate was that half of adults with incomes below 200% of the poverty level would switch between subsidized private insurance and Medicaid at least once a year due to income fluctuations.

Understand how premium subsidies are reconciled at tax time

Premium subsidies are available on “metal” plans if your household income is at least 100% federal poverty level (the limit is 139% in states that have expanded Medicaid). There is normally an income cap of 400% of the poverty level, above which subsidies are not available. But the American Rescue Plan has eliminated that upper income cap for 2021 and 2022. Subsidies are available for applicants with income over 400% of the poverty level if they would otherwise have to pay more than 8.5% of their income for the benchmark plan.

When you file your tax return, the correct subsidy amount is determined based on your actual income (as opposed to your projected income that was used when you enrolled). If your subsidy is overpaid throughout the year, you may have to pay back all or part of the subsidy, depending on your actual income for the year.

On the other hand, if your subsidy is underpaid throughout the year (ie, your income ends up lower than you projected, but still subsidy-eligible), you’ll be able to claim the rest of your premium tax credit when you file your tax return.

If you receive an advance premium tax credit and then your income actually ends up being under 100% of the poverty level, you do not have to pay back the subsidy; this is confirmed in the Form 8962 instructions (line 6, on page 8, under “Estimated household income at least 100% of the federal poverty line”; here’s what 100% of the poverty level translates to in terms of dollars).

But note that IRS Publication 974 does include a caveat, clarifying that the exception from the subsidy repayment rules for people with income under the poverty level “does not apply if, with intentional or reckless disregard for the facts, you provide incorrect information to the Marketplace for the year of coverage. You provide information with intentional disregard for the facts if you know that the information provided is inaccurate. You provide information with a reckless disregard for the facts if you make little or no effort to determine whether the information provided is accurate and your lack of effort to provide accurate information is substantially different from what a reasonable person would do under the circumstances.”

In other words, you cannot intentionally misrepresent your income as being over the poverty level and then avoid having to repay the subsidy that was paid on your behalf throughout the year. But it’s unclear how well that particular provision is able to be enforced. In implementing the (now defunct) 2019 rule that prevented a person from receiving a premium subsidy based on an attested income above the poverty level when government data show otherwise, HHS noted that “Particularly to the extent funds paid for APTC (for tax filers whose income ends up being under the poverty level) cannot be recouped through the tax reconciliation process, it is important to ensure these funds are not paid out inappropriately in the first instance.

On the other hand, if you pay full price for a private plan – expecting your income to increase – and then your income ends up being below 100% (139% in states that have expanded Medicaid) of the poverty level, there is no tax credit available to assist you, even if you’re in a state that has expanded Medicaid. You have to enroll in Medicaid when you’re eligible – there’s no provision for switching to Medicaid retroactively and recouping premiums you paid for private coverage.

So make sure you’re enrolled in a “metal” exchange plan during open enrollment (with premium subsidies if your projected income at that point makes you eligible) – or Medicaid if you’re eligible – and then keep the exchange updated during the year if your circumstances change.


Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org. Her state health exchange updates are regularly cited by media who cover health reform and by other health insurance experts.

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Ted Ballou
Ted Ballou
1 year ago

I am working with someone who was working at a salary just eligible for the subsidy; for health reasons she reduced her hours and finally had to quit and was unemployed for several months, without notifying the carrier. My questions: does the subsidy apply month to month, does she need to repay the subsidy received during the unemployment period or during the months when her salary was below the threshold, and is there additional penalty for neglecting to notify the carrier in a timely fashion? Finally, what is the mechanism to repay the subsidy? The software she used for federal taxes, HR Block, did not pick this up as an issue.
Thanks for your consideration of these issues.

Louise Norris
Louise Norris
1 year ago
Reply to  Ted Ballou

The subsidy is based on total annual income, regardless of whether that income is earned consistently throughout the year or in sporadic chunks. If income ends up below the subsidy eligibility level (ie, below the poverty level in states that haven’t expanded Medicaid, or below 138% of the poverty level in states that have expanded Medicaid), the IRS generally does not make a person repay the subsidy that they received based on a higher projected income. This is explained in more detail here: https://www.healthinsurance.org/faqs/if-my-income-is-less-than-expected-this-year-i-might-be-eligible-for-medicaid-what-can-i-do-during-open-enrollment-to-cover-my-bases/
Subsidy reconciliation is done via Form 8962, which she’d have to complete anyway, since she received a premium subsidy during the year. If the tax software didn’t flag it as an issue, it’s likely because the IRS generally does not make people repay premium subsidies in this situation. It’s important to note, however, that IRS Publication 974 (see the bottom of page 6: https://www.irs.gov/pub/irs-pdf/p974.pdf ) explains that the protection against having to pay back a subsidy if you’re income ends up being less than the poverty level does not apply if the applicant exhibited “intentional or reckless disregard for the facts” when reporting income information to the exchange, or if the “lack of effort to provide accurate information is substantially different from what a reasonable person would do under the circumstances.” In this case, she gave the exchange accurate information when she enrolled (based on her income at the time), but did not provide any updated information to the exchange when her income changed. I don’t know whether the IRS holds enrollees to the same standards in terms of updating the exchange as they do when people first enroll.

Sylvia
Sylvia
1 year ago

Qualified in 2020 for a ACA subsity. Due to a medical issue, what if I have “0” ncome for 2020?
I live in FL.

Louise Norris
Louise Norris
1 year ago
Reply to  Sylvia

Sylvia,
If you’re fairly certain that’s going to be your income level for the year, you’re supposed to report that income change to the exchange. But your premium subsidy will be eliminated at that point, since $0 income is too low for a subsidy. And since Florida has opted not to expand Medicaid, you’d be stuck in the coverage gap (that’s explained in more detail here: https://www.healthinsurance.org/faqs/what-is-the-medicaid-coverage-gap-and-who-does-it-affect/ If you lived in one of the 36 states where Medicaid has been expanded, you would become eligible for Medicaid when you report the income change, but unfortunately, Florida has chosen to not offer that option).
The IRS generally does not make people repay a premium subsidy that was based on accurate initial information but then ended up being too large (as would be the case for you, since your subsidy would reset to $0 based on having an income below the poverty level). I explain that in more detail here: https://www.healthinsurance.org/faqs/if-my-income-is-less-than-expected-this-year-i-might-be-eligible-for-medicaid-what-can-i-do-during-open-enrollment-to-cover-my-bases/
But Publication 974 (see the bottom of page 6: https://www.irs.gov/pub/irs-pdf/p974.pdf ) explains that the protection against having to pay back a subsidy if you’re income ends up under the poverty level does not apply if the applicant exhibited “intentional or reckless disregard for the facts” when supplying income information to the exchange, or if the “lack of effort to provide accurate information is substantially different from what a reasonable person would do under the circumstances.” That certainly applies to the initial enrollment process, but I’m not sure whether the IRS holds enrollees to the same standards in terms of reporting income changes to the exchange.
If you can manage to eke out an income of at least the poverty level ($12,490 this year for a single person, which is based on last year’s poverty level numbers), you’d still be fully eligible for a premium subsidy. And if that’s a lower income than you initially projected when you enrolled, you may end up receiving an additional premium subsidy from the IRS when you file your tax return next spring.

Sara
Sara
1 year ago

Because of an issue with my unemployment claim, I may possibly fall below the poverty level for 2020. I live in a state that did not expand Medicaid. When I enroll during open enrollment in November, it’s my understanding that Marketplace will refer to my 2019 tax return in which I did meet the poverty level. My projected income for 2021 will be the same amount as my 2019 income. Because Marketplace will not yet have my tax return for 2020 in which I may not meet the poverty level, do you anticipate any issue preventing me from enrolling in November? I believe my falling below the poverty level will not be an issue until open enrollment next year when Marketplace has my 2020 tax return on record. I believe I would then need to supply documentation to show I am no longer falling below the poverty level. Hopefully by then, we will have a better handle on COVID, and I can prove I am once again above the poverty level. Thank you!

Louise Norris
Louise Norris
1 year ago
Reply to  Sara

Yes, it should work the way you’re describing. If you’re projecting a 2021 income that matches what’s on file with your most recent tax return, you should be fine. A year from now, when they have your 2020 tax return on file and you’re enrolling in coverage for 2022, you’ll need to provide additional proof of income to show that your income has increased beyond what was reflected on your 2020 tax return.

Sara
Sara
1 year ago
Reply to  Louise Norris

Thank you so much! That is such a relief.

Natalia
Natalia
1 year ago

My parents are over 70 years old, live in Florida and are NOT eligible for Medicare. Are they eligible for Medicaid if their income is slightly higher than poverty line? (9% above it)? Thank you!

Louise Norris
Louise Norris
1 year ago
Reply to  Natalia

Are they ineligible for Medicare because they haven’t been in the US for at least five years? If so, they would also likely be ineligible for Medicaid. But if that’s the case, they can apply for a plan through HealthCare.gov (the exchange in Florida) and qualify for a premium subsidy to offset a significant amount of their premiums. They should also qualify for cost-sharing reductions with an income a little above the poverty level. You can use this tool to see the available plans in their area, how much the out-of-pocket costs are, and how much the premiums would be after the subsidies are applied: https://www.healthcare.gov/see-plans/#/ (these plans are typically thought of as coverage for people under age 65, but they’re also available for people over that age if they’re not eligible for Medicare).
In case it’s helpful, here’s more information about Florida Medicaid benefits for elderly residents: https://www.medicareresources.org/states/florida-guide-content/

Stephanie
Stephanie
1 year ago

I am 242percent above poverty annual income is 41k and the policy I signed up for I believe was 17k underestimate my income so my subsidy was paid all year how much will I owe the irs at then end of the year

JOEY WEAVER
JOEY WEAVER
9 months ago

Not sure if you are still answering questions but here is my dilemma. I receive an on-duty injury pension that is non-taxable therefore non-reportable as income per the IRS. My wife works part-time and earns below 10K but we had estimated her income above the Medicaid eligible level. !) Will we have to repay any subsidies for her marketplace insurance (she does get subsidies) 2.) Should we have estimated less or more than her yearly income? (3) By her income falling into Medicaid (again my income is non-reportable) I really don’t feel right about not declaring my injury income, is this a correct concern?

Louise Norris
Editor
9 months ago
Reply to  JOEY WEAVER

Joey,
If your injury pension income is non-taxable, it wouldn’t be included in your ACA-specific MAGI when everything gets reconciled with the IRS. The only non-taxable income that gets included is tax-exempt interest, non-taxable Social Security, and foreign earned income. Here’s more about how that works: https://www.healthinsurance.org/glossary/modified-adjusted-gross-income-magi/
However, since you’re a household of two (assuming it’s just the two of you), her income would need to be above the Medicaid eligibility level for a household of two in order to qualify for a premium subsidy in the marketplace. Assuming you’re in a state that has expanded Medicaid, that’s currently about $2,000 per month in income.
If she’s earning less than this and you’re in a state that has expanded Medicaid, she can switch to Medicaid. As noted in the article above, the IRS won’t make her repay her subsidy for the current year. But she won’t be able to re-enroll in a subsidized marketplace plan (as opposed to Medicaid) next year unless she can prove that her income has increased into the subsidy-eligible range by that point.

Mark
Mark
8 months ago

My 2020 income, including approximately $5,000 in UC benefits, was 139% of FPL. I did have an ACA plan in PA for 2020. With the new March2021 stimulus bill, I understand that the first $10,800 of UC benefits will not be taxed as income. If so, subtracting $5,000 from my MAGI would now put me below the 138% FPL required for subsidies in PA. Will I be required to pay back subsidies for a tax law that was made after the close of the tax year? (Had I known, I could have done a partial conversion of IRA to Roth IRA to cover that $5,000 but now it is too late.)

Louise Norris
Editor
8 months ago
Reply to  Mark

You’re in luck… nobody has to repay any excess premium subsidies from 2020. This is part of the American Rescue Plan as well: https://www.healthinsurance.org/blog/2021/03/10/how-the-covid-relief-law-will-rescue-marketplace-plan-buyers/

Lisa Davis
Lisa Davis
8 months ago

My son signed up for a ACA Marketplace plan in 2020 with an estimated income. He is a contract worker and self-employed artist. If he fell below the poverty level in 2020, can he continue his Marketplace coverage? He is in TN, so no Medicaid available.

Louise Norris
Editor
8 months ago
Reply to  Lisa Davis

Was he approved for a premium subsidy for 2021 based on his projected income for this year? If so, he should be good to go. If the marketplace is asking for updated proof of income, however, he would need to be able to show something that documents his projected income for this year being at least the poverty level in order to continue to receive premium subsidies.
His marketplace coverage, however, can continue either way (or if he’s newly enrolling now, during the COVID-related special enrollment period, he can sign up even if he’s not eligible for subsidies). But if he’s not eligible for subsidies due to his income, he’d have to pay full price in order to keep the premium in force. If his income picks up later in the year to at least the poverty level, he’d be able to provide proof of that to the marketplace in order to start getting a premium subsidy at that point. And the subsidies are bigger this year, thanks to the American Rescue Plan: https://www.healthinsurance.org/blog/2021/03/05/how-the-american-rescue-plan-act-would-boost-marketplace-premium-subsidies/

Laura Z
Laura Z
8 months ago

Thanks for the informative article, Ms. Norris. I was enrolled in Marketplace 2020 and eligible for PTC based on my estimated income and in hopes I would find a job paying what I previously made. I moved states (to Georgia) in August and notified marketplace and did a new enrollment application (did not have coverage for September because missed deadline). I put my new estimated income as $11,000 and I was not approved for PTC or eligible for Medicaid and paid full price for the premium ($533). I cashed out money from my stocks and thought it would go towards my AGI but turns out it was not taxable so My AGI for 2020 is below 100% of poverty line (80%) . My question: Can I still reconcile month Oct-Dec on form 8962 by filling out the SLCSP even though on 1095-A was $0 for that column and $0 PTC since I was originally approved and received PTC amounts the other months? I believe the other months should be okay since I did not overestimate my income with any “intentional disregard”, etc. I’m having a hard time understanding how those who made more money are getting relief with the American Rescue Plan and lower income people are not. So mad at myself as I really thought my stock cash out was going to count as income and wouldn’t have to deal with all this. Thanks for your time!

Louise Norris
Editor
8 months ago
Reply to  Laura Z

The problem, in this case, is that Georgia is one of the few remaining states that still refuse to expand Medicaid eligibility as called for in the ACA. In most states, a projected income of $11,000 would have made you eligible for Medicaid, which doesn’t have to be reconciled on your tax return. Unfortunately, Georgia hasn’t made that option available, despite the fact that the federal government would cover 90% of the cost (Georgia had previously agreed to implement a partial Medicaid expansion as of this coming summer, but with a work requirement).
You’re correct that you will not have to repay any APTC that was paid on your behalf for the first several months of 2020. This would be true even in a normal year, since the IRS does not make people repay APTC if their income ends up below the poverty level despite initial proof that it would be over that amount. But for 2020, nobody has to repay excess APTC, regardless of the reason: https://www.healthinsurance.org/blog/2021/03/10/how-the-covid-relief-law-will-rescue-marketplace-plan-buyers/
However, you will not be able to recoup any premium subsidies for the last few months of the year, since your income for the year ended up being below the subsidy-eligible level.
But as always in situations like this, we recommend that you reach out to a tax advisor to see if there’s anything they can recommend.

Laura Z
Laura Z
8 months ago
Reply to  Louise Norris

Thanks very much for your time and quick response!

James L Orr
James L Orr
8 months ago

My state is expanding medicaid on 7/1/2021. (Oklahoma)

I am doing IRA withdrawals to have income just above 100% poverty level which was fine at the time of the 2021 application for coverage.

Do I need to adjust IRA withdrawals to get over 139% in July, or am I good until the next enrollment period? I want to take what ever steps I need to take to continue my subsidy and not go into the medicaid pool.

Thanks for any guidance.

Louise Norris
Editor
8 months ago
Reply to  James L Orr

This is a good question, and you may get different answers depending on where you check. But according to HealthCare.gov, they do periodically check to determine whether enrollees might be Medicaid-eligible: https://www.healthcare.gov/medicaid-chip/cancelling-marketplace-plan/

I think it’s doubtful that they would automatically transition marketplace enrollees to Medicaid. In other states where Medicaid expansion has happened mid-year, we’ve seen a significant increase in Medicaid enrollment at the start of the following year, when marketplace enrollees have their eligibility redetermined during open enrollment – that’s what I’d expect to see in Oklahoma this fall. But your safest bet, given your intent to remain in the marketplace, would be to adjust your IRA withdrawals and notify the marketplace of your new income.

Jessie James
Jessie James
7 months ago

I retired early. I receive roughly $13500 from my pension. I have plenty of money in the bank to live on. When I applied for ACA at the beginning of the year, I stated that the difference between the $13500 from my pension and the minimum $18000 eligibility difference (Before I get kicked into Medicaid – Not acceptable!) was coming from retirement income. It was not a lie. When I retired, I cashed in my 407(b) so that I could manage it myself. I put all of it on a regular brokerage account from where I make monthly withdrawals. But now I realize Uncle Sam is not going to see that as retirement income for ACA purposes. I definitely do not want to get sent to Medicaid (Where I do not believe I would qualify because of money in savings). Does that mean I have to figure out a way to earn +/- $5000 before the end of the year? Thanks!

Louise Norris
Editor
6 months ago
Reply to  Jessie James

We advise that you consult with a tax professional on this. I’m not familiar with a 407(b), but maybe you were talking about a 403(b) or a 457(b)? In either case, if the account was a pre-tax retirement account (ie, not a Roth or funded with after-tax contributions), “cashing out” might mean that the entire amount is added to your taxable income for the year. If you did this in 2021, your income might end up making you ineligible for premium subsidies, meaning that you’d have to repay all of it (depending on the size of the account; there’s no longer a subsidy cliff in 2021 thanks to the American Rescue Plan, but extensive income, including one-time income, could still push a person above the point where a subsidy would be available based on the cost of the benchmark plan relative to income).

If you cashed out the account in a prior year and have already accounted for it in the tax return for that year, you can disregard the above. But you’re right — withdrawals from an account that’s already been taxed (as would be the case if you’ve cashed out a pre-tax retirement account and paid taxes on it at that point) are not going to count as income. Although if the money is invested and your withdrawals include sales that generate capital gains, the gains would be included in income.

But assuming that your taxable income for this year is actually going to end up at $13,500, you shouldn’t have to repay more than about $325 when you file your 2021 taxes. Table 5 of the instructions for Form 8962 have details: https://www.irs.gov/pub/irs-prior/i8962–2020.pdf Those numbers have not yet been indexed for 2021, but are likely to be in the same general ballpark (for 2020, nobody has to repay any excess subsidies, due to the American Rescue Plan: https://www.healthinsurance.org/blog/how-the-covid-relief-law-will-rescue-marketplace-plan-buyers/ ). As described in the article above, the IRS does not make people repay subsidies if their income ends up being under the poverty level, assuming they didn’t provide incorrect information “with intentional or reckless disregard for the facts.” But an income of $13,500 would be above 100% of the poverty level and below 200%, which is where the $325 repayment cap would come in (indexed for 2021).

Jessie James
Jessie James
6 months ago
Reply to  Louise Norris

Louise, Yes, I meant 457(b). Great information, thank you! I do not mind paying the extra $325 but I definitely do not want to be sent to Medicaid for obvious reasons. I wished I would have thought of this when I cashed out the 457(b). I was allowed to stay with my ex-employer’s group insurance and stuck with it until I realized the substantial savings under the ACA. Identical coverage and my payments are now much less than half of what I was paying. Even debt free and with money in the bank,it is a good chunk of change. I can’t even begin to imagine how anyone in less than ideal circumstances can pay for health insurance if not provided by employer (Especially if they have a family). Once again, thank you for your assistance. JJ

Max Weaver
Max Weaver
3 months ago

I projected my income to be 12800 for 2021 but I don’t know if my investments are going to get to that point. Should I just wait the rest of 2021 to see if I get to that level?

Louise Norris
Editor
3 months ago
Reply to  Max Weaver

We recommend that you consult with a tax advisor for specifics like this. But in general, the subsidies don’t have to be repaid if your income ultimately ends up under the poverty level, as long as you didn’t provide your estimate to the marketplace recklessly or with intentional disregard for the facts (ie, the projection had to be made in good faith).
It’s common for someone in this situation to try to obtain a small side job that could generate just enough income to ensure that they stay above the poverty level. This would help with future enrollments too, as the tax records on file would show that your income is over the poverty level.

Eric E
Eric E
3 months ago

My wife and daughter are on Medicaid but I and my sons are covered by an ACA marketplace plan and receiving subsidies. My income rose to no longer be covered by Medicaid, but due to the pandemic, my state is not canceling Medicaid plans due to income.

They did notify my daughter’s plan would be canceled due to it expiring in June, so when they did that I signed her up for an ACA plan and ran into no problem. Then they sent me a notice that my wife’s plan would be expiring in August, so I went to go sign her up, but I happened to double check online and… it turns out Medicaid renewed both my wife AND my daughter through next year (due to the pandemic), but they failed to notify me about it. I called my state’s Medicaid program and they confirmed that yes they were renewing plans automatically, and in their system it wasn’t even possible for them to disqualify an applicant.

So now, in August I’m call the Marketplace back and try to get them to backdate my daughter’s cancellation to when she started under the plan (they were able to do that last year when my wife found out she was pregnant and Medicaid backdated her approval), but the Marketplaces denied it backdating the cancellation.

Does that mean when it’s time for tax season I’m going to have to pay back the ACA credit for the period she was double-enrolled but still pay the higher bill at the insurer? Is there any way around this since they did inform me it would be canceled and then renewed her without informing me?

If I found some way to cancel Medicaid I’m sure they wouldn’t accept us back as a new application, if I cancel Medicaid would I then be ineligible and qualify for ACA subsidies then?

Louise Norris
Editor
3 months ago
Reply to  Eric E

Eric,
I’m sorry you’re in this situation. Have you tried escalating this situation to a supervisor at the Marketplace, and have you submitted proof to the Marketplace, showing that the Medicaid coverage was renewed in June?

Eric E
Eric E
3 months ago
Reply to  Louise Norris

Tried escalating to the supervisor, they said the only way they could backdate is if I had called previously and they had failed to cancel at the time. When asking for other options to escalate beyond that person, she said my only option was to write the marketplace contact center via physical mail and gave me their address.

Louise Norris
Editor
3 months ago
Reply to  Eric E

I would advise calling back again to see if you get a different person. Someone should be able to get this sorted out for you, as long as you have documentation of everything that has happened with Medicaid (ie, the information that the plan was expiring in June, as well as the subsequent renewal – and if possible, something from Medicaid confirming that they didn’t send you any notification that the coverage was being renewed back in June). If you can get the state Medicaid department involved as well, that would be ideal. Possibly a three-way phone call with Medicaid and the Marketplace?

T J
T J
2 months ago

While I do NOT have income less than expected this year, I have a SIMILAR SITUATION that is unexpected increase in the required minimum income for Obamacare, as Missouri just expanded Medicaid mid year, so I thought I would ask this here, being a similar question….

My income has been in the range of 100-133% of poverty line every recent year through and including my 2020 tax return, and I have been getting insurance on the exchange as a Missouri resident.

While Missouri just expanded medicaid, the news indicates the state will not fully process applications for the newly eligible till October, despite court orders to accelerate the process.

When I purchased insurance on the exchange for this year, I estimated my income in the same usual range. Based on what I have received this year, it looks like my income will be close to my estimate, however, I may earn a larger amount to go above 138% poverty by the end of the year, but have no proof (I am self employed and my income is irregularly spaced).

How quickly do I need to apply for Medicaid to avoid risk of having to pay back my subsidies for remaining on marketplace plan while too poor to qualify for the subsidy? Do I need to do this now, or would it be at time of my reapplication at the end of the year (if my actual income this year does not climb over 138%)?

(I would like to try to avoid Medicaid because it requires Managed Care like HMOs and I am concerned of the quality of care I would receive.)

Thanks

Louise Norris
Editor
2 months ago
Reply to  T J

You should be ok to stay on your current plan, with your current subsidies, for the rest of 2021. See the bottom of page 4 on the instructions for Form 8962, under the heading “Medicaid and CHIP”: https://www.irs.gov/pub/irs-pdf/i8962.pdf Basically, since you gave the marketplace accurate income information when you enrolled in a plan for 2021, the fact that they found you ineligible for Medicaid (and eligible for subsidies) at that point is valid throughout the plan year.
But during the upcoming open enrollment period this fall, you’ll need to sort things out for 2022 — either by enrolling in Medicaid or being able to show proof (if requested) of an income above 138% FPL.

Rob
Rob
2 months ago

I have family that lives in Texas and for 2020 showed 16,000 as their income for a household of 2. That is about $2,000 below the poverty level for that size household. They believe they are on track to pass the $18,000 threshold for 2021. They are currently uninsured. I know they just missed the expanded open enrollment period, but would they be able to get a SEP for change of income?

Louise Norris
Editor
2 months ago
Reply to  Rob

Yes, if they can show proof of the increased income. Here’s more about the special enrollment period that’s available for a household that experiences an income change that gets them out of the coverage gap: https://www.healthinsurance.org/special-enrollment-guide/leaving-the-coverage-gap-this-sep-is-for-you/

Meg
Meg
1 month ago

So my state medicaid will not annualize me. I have a contract for 9month work and if you take the day I work 184 a year times my rate divide by 12 months I qualify for the state medicaid however they don’t do that so they base me off of monthly in the long run I make less then someone who would qualify with a 12 month job and in the long run they will have more money in a year then me. What do I do for my child? I’m mind blown because HUD tell me I’m below poverty but medicaid says nope

Louise Norris
Editor
1 month ago
Reply to  Meg

I’m sorry you’re in this situation, and I’d encourage you to contact your state Medicaid agency again, just to make sure you get the same answer from another representative. States have the option to use projected annualized income in situations like you’re describing, but are not required to do so: https://www.medicaid.gov/state-resource-center/mac-learning-collaboratives/downloads/part-2-income.pdf

However, children are eligible for Medicaid or CHIP with much higher household incomes than adults. This is true in every state, although the specifics do vary from state to state: https://www.medicaid.gov/medicaid/national-medicaid-chip-program-information/medicaid-childrens-health-insurance-program-basic-health-program-eligibility-levels/index.html So even if your current monthly income puts you a little over the Medicaid threshold for yourself, your child should still be eligible for either Medicaid or CHIP.

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