Q. I saw that the percentage of income I have to pay for my health insurance is going back down again for 2020, after declining for 2018 but then increasing for 2019. Does that mean the IRS is saying that I don’t have to pay as much for my health insurance next year?
A. Maybe. But if you experience an increase in your income, or if you select a more expensive plan, that would no longer be the case. And you also have to take into account how benchmark premiums are changing relative to the premium for your plan, as that’s a significant factor in how much you’ll pay in after-subsidy premiums. Let’s take a look at how it all works:
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 would have to pay (known as the applicable percentage) if they selected 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 detailed the changes for 2017.
For 2015, 2016, and again for 2017, there was a slight increase in the applicable percentage numbers. Because the applicable percentage climbed each year, there was often an assumption that everyone who gets subsidies was paying more for their health insurance (after subsidies) in each successive year. But that’s not necessarily the case, as we’ll see in a minute.
Applicable percentages decreased for 2018
And for 2018, the applicable percentages decreased slightly when compared with 2017, meaning that the percentage of income that people had to pay (after subsidies) for their coverage was slightly lower at all income levels than it was in 2017. (See Revenue Procedure 2017-36 for 2018 numbers.)
This means that before accounting for other factors (including age and income changes), people buying coverage for 2018 had to pay a slightly smaller portion of their income for the second-lowest-cost Silver plan than they paid in 2017. (Income is based on how it compares with the FPL (federal poverty level), which increased to $12,060 for a single person in 2017; the 2017 FPL guidelines were used to determine subsidy eligibility for anyone enrolling in a plan with a 2018 effective date.)
In 2018, people who were eligible for premium subsidies had to pay between 2.01 percent and 9.56 percent of their income for the benchmark plan in their area. Of course, people don’t have to pick the benchmark plan – they can pick a higher-cost plan and pay more, or they can pick a lower-cost plan and pay less.
Applicable Percentages increased for 2019
For 2019, the applicable percentages went back up again, and are higher than they’ve been in any previous year. But as described below, people who are subsidy-eligible and whose income hasn’t increased since 2014 are paying less in after-subsidy premiums in 2019 than they were paying in 2014 (assuming they selected the benchmark plan in both years), due to the annual growth in the poverty level since 2014.
The details for 2019’s applicable percentages are in Revenue Procedure 2018-34. The 2018 federal poverty level guidelines are used to determine subsidy eligibility for 2019 coverage (so the poverty level for a single person is $12,140). For 2019 coverage, people who are eligible for premium subsidies pay the following percentages of their income for the second-lowest-cost silver plan, after subsidies:
- Income less than 133% of poverty = 2.08%
- At least 133%, but less than 150% = 3.11% to 4.15%
- At least 150%, but less than 200% = 4.15% to 6.54%
- At least 200%, but less than 250% = 6.54% to 8.36%
- At least 250%, but less than 300% = 8.36% to 9.86%
- At least 300%, not more than 400% = 9.86%
But they’re decreasing again for 2020
For 2020, the applicable percentages will decrease again. The details are in Revenue Procedure 2019-29, which was published in July 2019. For 2020 coverage, people who are eligible for premium subsidies will pay the following percentages of their income, after the subsidy is applied, for the second-lowest-cost silver plan (ie, the benchmark plan):
- Income less than 133% of poverty = 2.06%
- At least 133%, but less than 150% = 3.09% to 4.12%
- At least 150%, but less than 200% = 4.12% to 6.49%
- At least 200%, but less than 250% = 6.49% to 8.29%
- At least 250%, but less than 300% = 8.29% to 9.78%
- At least 300%, not more than 400% = 9.78%
Making sense of applicable percentages
Those numbers might make your eyes glaze over. But the following examples will show how they actually affect premiums from one year to the next. The first set of examples show how Bob’s premiums change from 2014 to 2019, and what will happen in 2020, if his income increases each year to keep pace with increases in the federal poverty level. Below that, you’ll see what happens if Bob’s income hasn’t increased since 2014. Yes, there’s math involved, but never fear — it’s pretty straightforward.
Example: Bob’s premium changes from 2014 to 2020, if he gets annual raises that keep his income at 200% of the poverty level
Bob’s 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, for 2018, it was 6.34 percent, for 2019, it’s 6.54 percent, and for 2020 it will be 6.49 percent, assuming that he gets a raise each year so 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 open enrollment period for 2019 coverage took place in 2018, the government uses 2018 poverty level guidelines for determining subsidy-eligibility for any plans that have 2019 effective dates. Similarly, subsidy eligibility for 2020 coverage will be based on the 2019 poverty level guidelines (poverty level numbers are published by HHS in January each year, but that’s after open enrollment for that year’s coverage has already ended).
2014: $1,448 in premiums, with an income of $22,980
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 had 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 paid the rest of the premium, assuming he selected the second-lowest-cost silver plan (ie, the benchmark plan).
2018: $1,529 in premiums, with an income of $24,120
But for 2018, if Bob was still earning 200 percent of poverty level, his MAGI had increased to $24,120, since the poverty level has increased. His applicable percentage was 6.34 percent, which equaled $1,529 in annual premiums ($24,120 x 0.0634). That’s about $81 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 $1,140 additional dollars per year.
So while his net premium had increased, his income was also increasing (and note that this is comparing his premiums in 2014 with his premiums in 2018; if we just look at 2017 versus 2018, the slight decrease in the applicable percentage for 2018 nearly exactly offsets the increase in the poverty level, making his net premium just about exactly the same in 2018 as it was in 2017).
2019: $1,588 in premiums, with an income of $24,280
For 2019, the applicable percentage increased again, and the poverty level has also increased. (2018 poverty levels were higher than they were for 2017.) If Bob is still earning 200 percent of the poverty level when he signs up for 2019 coverage, it means his income has grown to $24,280. He’ll have to pay 6.54 percent of that for the second-lowest-cost Silver plan, which will come to $1,588 in annual premiums ($24,280 x 0.0654). So Bob is paying $140 more in annual premiums in 2019 than he was paying in 2014 — but his income is $1,300 higher than it was in 2014, since we’re assuming he’s stayed at 200 percent of the poverty level.
2020: $1,621 in premiums, with an income of $24,980
For 2020, the applicable percentage will decrease, but the poverty level will continue to increase. To keep Bob at 200 percent of the poverty level, his income will have to grow to $24,980 for 2020 (based on 2019 poverty level numbers, since that’s what’s used for the 2020 coverage year). He’ll pay 6.49 percent of his income for the benchmark Silver plan, which will amount to $1,621 in annual net premiums. That’s $33 more in annual premiums than he paid in 2018, and $173 more than he paid in 2014. But his income in 2019 is $2,000 higher than it was in 2014.
What if Bob doesn’t get a raise?
But what if he doesn’t get a raise, and his MAGI is still $22,980 in 2019? That means his income is now 189 percent of poverty level, instead of 200 percent, so his applicable percentage is less than 6.54 percent in 2019 ($22,980 divided by $12,140 is 1.89; that means Bob’s income is 189 percent of the 2018 federal poverty level, which we use to calculate 2019 subsidy eligibility).
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:
189 – 150 = 39
200 – 150 = 50
39/50 = 0.78
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 78 percent of the way along the range that goes from 150 to 200 percent of poverty.
6.54 – 4.15 = 2.39
2.39 x 0.78 = 1.86
4.15 + 1.86 = 6.01
The second part of the calculation is to look at the applicable percentage range that corresponds to Bob’s income range (4.15 to 6.54 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 78 percent of the way along that applicable percentage range. In Bob’s case, it’s 6.01 percent.
His applicable percentage for 2019 is 6.01 percent, and his net premium (after his subsidy is applied) is actually lower in 2019 than it was in 2014. It will be 6.01 percent of $22,980, which is $1,381 in annual premiums. That’s about $67 less than he had to pay in 2014 for the second-lowest-cost Silver plan.
But if you did that same math for 2018, Bob’s applicable percentage was 5.92 percent (assuming his income was unchanged at $22,980, and using the 2018 applicable percentage chart). That meant he was paying $1,360 in annual premiums in 2018. So while his after-subsidy premium in 2019 for the second-lowest-cost silver plan is less than it was in 2014 (assuming his income remains constant for all of those years), his annual premium is higher in 2019 than it was in 2018, by about $21.
If we run the same calculations for 2020, continuing to use an income of $22,980, Bob’s income will be 183 percent of the poverty level and his applicable percentage will be 5.68 percent. So his net premium for the benchmark silver plan will be $1,305 in 2020 — lower than it was in 2014, 2018, and 2019. That’s because Bob’s income hasn’t kept pace with the poverty level, so the amount he has to pay in net premiums has declined over time.
Applicable percentages increased for 2019, but so did the poverty level – and you have to consider them together
There are a lot of moving parts here. Although the applicable percentages for 2019 are the highest they’ve been since this system was implemented, the poverty level is also the highest it’s ever been. So people whose incomes have not increased in several years could find that they’re paying less in total premiums in 2019 than they were paying a few years earlier.
As described above, they may have seen at least a small increase in after-subsidy premiums from 2018 to 2019, unless their income has decreased. But keep in mind that the applicable percentages decreased in 2018, resulting in a drop in after-subsidy premiums even for people whose income increased slightly in 2018.
How the applicable percentage is calculated — it’s changed a bit in recent years
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 health care costs increase faster than income, we all have to pay a larger chunk of our income for health care. But 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 — as was the case for 2018, and as will again be the case for 2020.
The formula for the adjustment to applicable percentage is just premium growth since 2013 divided by income growth since 2013. But the methodology for calculating each of those numbers has changed over time.
Premium growth used to be based on average per-enrollee premiums for employer-sponsored plans, in terms of how much those premiums had changed since 2013. But for 2020, HHS finalized a methodology change that incorporates premium changes in the individual market, as well as premium changes for employer-sponsored plans.
This was widely expected to result in an increase in applicable percentages for 2020, but when the numbers were published in July 2019, the applicable percentages for 2020 were lower than they had been for 2019 (without the methodology change, applicable percentages would likely have decreased even more for 2020, as the estimation was that they would be 2.7 percent higher in 2020 with the new calculations that incorporate premium changes in the individual market).
Income growth was based on changes in GDP per capita for plan years 2014 through 2016, but HHS finalized a new formula that has been used to calculate income growth since 2017. The new formula calculates 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.
The IRS also added a provision that allows for an additional adjustment for years after 2018 to reflect the premium growth rate relative to the growth in the consumer price index [the additional adjustment is described in §36B(b)(3)(A)(ii)(II)]. But the next section in that code [§36B(b)(3)(A)(ii)(III)] says that the additional adjustment is only needed if the total amount the government spent on premium subsidies and cost-sharing reductions in the previous year was more than 0.504 percent of the previous year’s gross domestic product. For 2019, and again for 2020, the IRS determined that the additional adjustment is not necessary.
Since subsidies are also a function of the 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.
Benchmark premiums are slightly lower in 2019 in most states, which means subsidies are slightly smaller
Premium subsidy amounts are based on the relationship between an applicant’s income and the federal poverty level, but they’re also highly dependent on the premium that the applicant would have to pay for the benchmark plan. The formula described above is how subsidy amounts are determined in every state (keeping in mind that Alaska and Hawaii have their own poverty level numbers).
But what if you don’t buy the benchmark plan? Many areas have 20 or more plans available for sale in the exchange, and only one of them is the benchmark plan (it changes from year to year, but it’s always the second-lowest-cost silver plan). If you buy a plan that’s not the benchmark plan and you’re eligible for a subsidy, you still get the same subsidy amount that you’d have received if you had purchased the benchmark plan, but it’s applied to the price of the plan you select instead.
Nationwide, average premiums in the individual market were slightly higher for 2019 than they were in 2018. But in the 39 states that use HealthCare.gov, average benchmark premiums were slightly lower than they were in 2018 (in some areas this is because an existing insurer lowered their rates, but in other areas it’s because a new insurer joined the market and began offering lower-priced silver plans than the ones that were already available — the Phoenix area is an example).
Across all HealthCare.gov enrollees who are receiving premium subsidies, the average subsidy amount was $550/month in 2018, and has dropped to $539/month in 2019. But as we saw above, the whole point of premium subsidies is to cover the difference between the actual cost of the benchmark plan and the amount the enrollee is expected to pay for that plan based on a specific percentage of their income. So even if the amount the enrollee is expected to pay remains unchanged, the premium subsidy amount will go down if the full-price cost of the benchmark plan goes down. For some enrollees, premiums are higher in 2019, but other enrollees have lower premiums in 2019 — and there are several factors involved in how much the net premium changes.
The best course of action is to actively shop for your coverage each year during open enrollment. Never let your plan automatically renew without checking first to make sure that it’s still the best option. In most states, open enrollment runs from November 1 to December 15, with all plans effective on January 1. That open enrollment window is your only opportunity to make changes to your coverage for 2020 unless you experience a qualifying event.
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.