Q. I saw that the percentage of income I have to pay for my health insurance is going up again for 2017. Is the IRS saying I’ll have to pay more for my health insurance next year?
A. The ACA has a lot of moving parts. Various aspects of the regulations have to be updated annually, including the affordability rules.
Initially, the IRS laid out guidelines detailing the percentage of tax filers’ income that they would be expected to contribute towards their own premiums, assuming their income doesn’t exceed 400 percent of the poverty level.
Then in July 2014, the IRS released Revenue Procedure 2014-37, in which they explained the changes to the percentage of income that subsidy recipients will have to pay (known as the applicable percentage) if they select the second-lowest-cost Silver plan in the exchange in 2015.
A few months later, in November 2014, the IRS published Revenue Procedure 2014-62, which laid out the changes to the applicable percentage for 2016. And in 2016, they published Revenue Procedure 2016-24, which details the changes for 2017.
For 2015, 2016, and again for 2017, there is a very slight increase in the applicable percentage numbers. Because the applicable percentage is going up, some people have assumed that everyone who gets subsidies will be paying more for their health insurance in 2017. But that’s not necessarily the case.
Here are the updated applicable percentages for the subsidy-eligible income ranges in 2017. (Income is based on how it compares with the federal poverty level, which has increased to $11,880 for a single person in 2016; the 2016 FPL guidelines will be used to determine subsidy eligibility for anyone enrolling in a plan with a 2017 effective date.)
- Income less than 133% of poverty = 2.04%
- At least 133%, but less than 150% = 3.06% to 4.08%
- At least 150%, but less than 200% = 4.08% to 6.43%
- At least 200%, but less than 250% = 6.43% to 8.21%
- At least 250%, but less than 300% = 8.21% to 9.69%
- At least 300%, not more than 400% = 9.69%
Case in point: Bob
Let’s consider Bob, whose MAGI (modified adjusted gross income as calculated for the ACA’s premium tax credits) is equal to 200 percent of poverty. In 2014, his applicable percentage was 6.3 percent, and for 2016, it will be 6.43 percent, assuming that his MAGI remains at 200 percent of poverty throughout that time frame.
For subsidy purposes, poverty level determinations are based on the year during which open enrollment begins. Since the 2017 open enrollment is beginning in 2016, they will use 2016 poverty level guidelines for determining subsidy-eligibility for any plans that have 2017 effective dates.
If Bob was earning 200 percent of poverty level when he got his 2014 plan, his MAGI was $22,980 (based on the 2013 poverty level) and his applicable percentage (the amount he has to pay for the second-lowest-cost Silver plan) was 6.3 percent. So he had to pay $1,448 in annual premiums in 2014 ($22,980 x 0.063). His subsidy pays the rest of the premium, assuming he selected the second-lowest-cost Silver plan.
But going into the 2017 open enrollment, if Bob is still earning 200 percent of poverty level, his MAGI has increased to $23,760, since the poverty level has increased. His applicable percentage will be 6.43 percent, which equals $1,528 in annual premiums ($23,760 x 0.0643). That’s about $80 more in annual premiums than he had to pay in 2014. But in order to maintain his percentage of poverty level at 200 percent, he’s earning $780 additional dollars per year. So while his net premium has increased, his income is also increasing.
But what if he doesn’t get a raise, and his MAGI is still $22,980? That means his income is now 193 percent of poverty level, instead of 200 percent, so his applicable percentage will be less than 6.43 percent in 2017.
To calculate applicable percentages for incomes that are somewhere within each range on the chart, you can use the formula that’s explained in CFR 1.36B-3. (Scroll down to just underneath the applicable percentage chart, and look at example 2.) In the case of Bob, it looks like this:
193 – 150 = 43
200 – 150 = 50
43/50 = 0.86
Basically, you look to see what income range you’re in. (Bob is between 150 and 200 percent of poverty range.) Then you just figure out how far along the income range you are. In this case, Bob’s income is 86 percent of the way along the range that goes from 150 to 200 percent of poverty.
6.43 – 4.08 = 2.35
2.35 x 0.86 = 2.02
4.08 + 2.02 = 6.1
The second part of the calculation is to look at the applicable percentage range that corresponds to Bob’s income range (4.08 to 6.43 percent – meaning that the percentage of income he’ll have to pay for the second-lowest-cost Silver plan is somewhere between those two percentages). And then you just figure out what number is 86 percent of the way along that applicable percentage range. In Bob’s case, it’s 6.1 percent.
His applicable percentage will be 6.1 percent, and his net premium will actually be lower in 2016 than it was in 2014. It will be 6.1 percent of $22,980, which is $1,402 in annual premiums. That’s about $46 less than he had to pay in 2014 for the second-lowest-cost Silver plan.
Applicable percentages higher, but so is FPL
There are a lot of moving parts here. Although it’s true that the applicable percentages are once again increasing slightly for 2017, the poverty level is also increasing. So people whose incomes are not increasing will be at a lower percentage of poverty level than they were the year before, which means their applicable percentage could decrease rather than increase.
Since poverty level is higher than it was last year, your income will have to increase in order to keep your percentage of poverty level unchanged. If that happens, your applicable percentage will increase – but only by somewhere between 0.03 and 0.02 of a percent.
The general idea behind the adjustment to the applicable percentage table is to keep up with changes in premium growth as they relate to changes in income. If healthcare costs increase faster than income, we all have to pay a larger chunk of our income for healthcare. But in future years, if the economy does well and the ACA’s efforts to curb healthcare spending are successful, it’s also possible for the applicable percentage to decrease.
The formula for the adjustment to applicable percentage is just premium growth since 2013 divided by income growth since 2013. Premium growth is based on average per-enrollee premiums for employer-sponsored plans, and they calculate how much those premiums have changed since 2013. Income growth was based on changes in GDP per capita for plan years 2014 through 2016, but HHS finalized a new formula that will be used to calculate income growth starting in 2017. The new formula will calculate income growth based on per-capita personal income (PI) rather than per-capita GDP. The two methods would likely generate similar numbers, but HHS considers per-capita PI changes to be a more accurate reflection of how per-capita income changes from one year to the next.
Since subsidies are also a function of poverty level – which generally adjusts upward each year – there’s a built-in factor that essentially ensures that people who are impacted by a higher applicable percentage are also enjoying at least a modest increase in income that outweighs the additional premiums.