If the Senate and House both pass the Inflation Reduction Act, the current marketplace subsidy structure will remain in place through the end of 2025, instead of expiring at the end of 2022. This would help marketplace shoppers in several ways:
The subsidy cliff would continue to not exist for the next three years, meaning that Americans with income above 400% of the federal poverty level (FPL) would still be potentially eligible for subsidies. Subsidy eligibility would depend on the percentage of income that a person would have to spend on the benchmark plan, and subsidies would be available – even with income above 400% of FPL – if the benchmark plan would otherwise be more than 8.5% of household income.
Subsidies would continue to be larger than they were pre-ARP. The size of the subsidies varies by income, age, and area, but they limit the after-subsidy cost of the benchmark plan to a pre-determined percentage of household income. That percentage of income is on a sliding scale, and the ARP reduced it to 0% – 8.5%. Under the ACA, it had been 2% – 9.5%, with small annual inflation adjustments. With the ARP in place, the 0% – 8.5% scale has been used for 2021 and 2022 health plans. And the Inflation Reduction Act would lock in that same scale through the end of 2025.
The ongoing marketplace special enrollment period for subsidy-eligible applicants with household income up to 150% of FPL would continue to be available through 2025. HHS has clarified that this enrollment opportunity is only available as long as benchmark plans are premium-free for buyers at this income level. If the ACA’s scale were to return, subsidy-eligible applicants at the lower end of the income scale would pay roughly 2% of their income for the benchmark plan. But with the ARP’s scale in place, these applicants pay 0% of their income for the benchmark plan. The Inflation Reduction Act would continue that for three more years, allowing the special enrollment opportunity to continue as well.