What is the American Rescue Plan (ARP)?

ARP is legislation enacted in March 2021 in response to COVID-19 designed to provide financial relief to Americans, including improving the affordability of health insurance purchased through the Affordable Care Act (ACA) Marketplace. ARP expands the financial assistance available, so more Americans are eligible and can receive help paying for their health insurance. This may lower the monthly premiums for people who currently have or will enroll in a Marketplace health plan.

How has eligibility for financial assistance changed through ARP?

ARP temporarily expands advanced premium tax credits (APTC) to individuals with incomes above 400 percent of the federal poverty level (FPL), and it increases the amount of the tax credits for those with incomes between 100 and 400 percent FPL.

When will these changes be effective?

• The new APTC eligibility guidelines will appear on the Marketplace beginning April 1, 2021.
• Consumers may enroll in a Marketplace plan until the end of the Special Enrollment Period (SEP), which is currently August 15.
• Members may change their plan until the end of the SEP.
• Members may complete the re-determination process for additional APTC anytime in 2021 by updating their Marketplace application and re-selecting their plan.
• Updated tax credits and lower premiums would begin the following month.

How long will the changes be in effect?

The updated eligibility guidelines will remain in effect through the end of 2022.  

Does this impact anyone with group coverage?

No, this will have no impact on anyone with group coverage. The APTC tax credits are not available for those covered under employer-sponsored group coverage.

What does this mean for current members?

Current members (including those who enrolled during the SEP) who weren’t originally eligible for financial assistance could now be eligible. Also, current members who are currently receiving financial assistance could be eligible for additional assistance.

What actions do members need to take to see the savings this year?

Currently, the Marketplace will not automatically update subsidy eligibility on behalf of current members. Here is what members need to do:

• Marketplace members receiving a subsidy: update their Marketplace application after April 1 to see if they are eligible for additional tax credits. 
• Marketplace members not receiving a subsidy: update their Marketplace application after April 1 to see if they are now eligible for tax credits.
• Private Marketplace members: create a Marketplace application and provide their financial information to determine if they are now eligible for tax credits. 
• The updated tax credits would begin the following month. 
   

Do current BlueCross Marketplace members have to do anything?

No, Marketplace members may receive the additional tax credit amount (if eligible) next year when they file and reconcile their 2021 federal income taxes, if they do not take any additional action this year.

If a current BlueCross BlueShield of South Carolina member chooses a new BlueCross ACA plan, will their incurred deductible and maximum out-of-pocket transfer to the new policy?

Yes, any deductible or maximum out-of-pocket accumulated during the 2021 plan year will transfer to the new policy regardless of metal band, as long as the plan is a BlueCross ACA plan.

Does this impact a member’s current coverage?

No. A member’s coverage will not change unless they actively switch to a new plan prior to August 15.

I enrolled in a Private Marketplace plan. Can I switch to a Marketplace plan to take advantage of the additional financial assistance?

Yes. During the SEP, Private Marketplace members can switch to a plan on the Marketplace. 

What if a member received too large of subsidies in 2020?

ARP removes the requirement to pay back any extra subsidy received in 2020. Members who have not yet filed their 2020 taxes will not be required to pay back excess subsidies received last year. Members who have already filed their taxes and paid back 2020 subsidies should contact their accountant.

What if a member is receiving unemployment compensation?

For the purpose of calculating APTC eligibility, members who received unemployment compensation during any week in 2021 will have their income treated as 133% of the FPL, regardless of their total annual income. More guidance regarding how a consumer receives this benefit will be provided at a later date.