Health Reform | Benefits @ Work

Health Insurance Marketplace Subsidy Notices

Posted on August 3, 2016 by jburgess10

Have you received a Health Insurance Marketplace Subsidy Notice (Subsidy Notice) from the Department of Health and Human Services (HHS)? If so, your response may affect whether or not the IRS later assesses a pay or play penalty. This article explains the appropriate way to respond to these notices.

Background
HHS recently began sending Subsidy Notices to employers. The purpose of the Subsidy Notice is to inform employers that an individual—who identified the employer as his or her employer—enrolled in health insurance through the Health Insurance Marketplace and was certified as eligible for an Advanced Payment of Premium Tax Credit (APTC).

Pay or play penalties are potentially triggered when at least one of an applicable large employer’s (ALE) “full-time employees” (as that term is defined under the Affordable Care Act or ACA) receives an APTC.

Subsidy Notices are sent by HHS. Only the IRS can assess a pay or play penalty. So, it is important for employers to understand:

The Subsidy Notices do not determine whether the employer is subject to a pay or play penalty; and
Failure to appeal the Subsidy Notice does not preclude the employer from later appealing the assessment of a pay or play penalty by the IRS.

Applicable Large Employer Responses to Subsidy Notices
First and foremost, an employer should not appeal a Subsidy Notice on behalf of an employee for whom the employer did not: (1) offer coverage under its group health plan; or (2) offer coverage that was both affordable and of minimum value.

As explained below, however, employers should carefully consider whether to appeal the Subsidy Notices received on behalf of other employees—especially full-time employees—who were offered coverage under the employer’s group health plan that is both affordable and of minimum value.

Full-Time Employees
Only full-time employees can trigger a pay or play penalty. If an employer receives a Subsidy Notice on behalf of a full-time employee who was offered affordable, minimum value coverage, it may be in the employer’s best interest to appeal the Subsidy Notice. This may allow the employer to “nip in the bud” the issue of a later assessment of a pay or play penalty by the IRS. (Alternatively, if the IRS still assesses a pay or play penalty on behalf of a full-time employee who the employer successfully appealed a Subsidy Notice, the evidence of the successful appeal may be helpful to the employer in contesting the IRS’s assessment of a pay or play penalty.)

It may not only be in the employer’s best interest to appeal the Subsidy Notice—it may also be in the employee’s best interest because the employee may be ineligible for the APTC. In other words, a successful appeal of the Subsidy Notice may also limit the amount of the APTC that the ineligible employee must repay.

Non-Full-Time Employees
A non-full-time employee cannot trigger a pay or play penalty. So, it is unnecessary to appeal a Subsidy Notice received on behalf of a non-full-time employee for purposes of the pay or play penalty.

If an ALE offered a non-full-time employee affordable, minimum value coverage, however, the ALE may want to appeal the Subsidy Notice to limit the amount of the APTC that the employee must repay.

Non-Applicable Large Employer Responses to Subsidy Notices
Non-ALEs (generally employers with less than 50 full-time and full-time equivalent employees) are not subject to the pay or play penalty. So, again, there is no reason for a non-ALE to appeal a Subsidy Notice for pay or play penalty purposes.

But a non-ALE may consider appealing a Subsidy Notice on behalf of an employee who was offered affordable, minimum value coverage, to limit the amount of the APTC that the employee must repay.

How to Appeal the Subsidy Notice
To appeal the Subsidy Notice, an employer should use the form provided by HHS, which is available at healthcare.gov (https://www.healthcare.gov/marketplace-appeals/employer-appeals). This form provides a space for the employer to include a narrative explaining why the employee is ineligible for an APTC. In this narrative, the employer should indicate that the employee was either enrolled in coverage under the employer’s group health plan or that the employee was offered coverage under the employer’s group health plan. The employer should also include the employee’s cost of employee-only coverage under the employer’s lowest-cost group health plan and an affirmative statement that the group health plan provides minimum value.

In addition to the narrative, the employer may include supporting documentation, such as:

A copy of the election form (or a screenshot from an electronic enrollment platform) showing that the employee is enrolled in the employer’s group health plan, or was offered and waived coverage under the employer’s group health plan.
If the employee didn’t affirmatively waive coverage, the employer should include plan records showing that the employee was offered coverage but failed to elect coverage under the employer’s group health plan.
Any materials evidencing the employee’s cost of coverage. (Evidence of satisfying an affordability safe harbor may be helpful, but will not be determinative of actual affordability.)
Evidence that the employer’s group health plan is of minimum value (e.g., a summary of benefits showing that the group health plan covers at least 60% of eligible expenses).
A copy of the Subsidy Notice

Conclusion
As a reminder, an ALE’s decision to appeal Subsidy Notices has no bearing on the ALE’s ability to later appeal the IRS’s assessment of a pay or play penalty. But being proactive in appealing Subsidy Notices may prevent the IRS from later assessing a pay or play penalty.

If you have any questions about Subsidy Notices or how you should respond, please contact the Benefit Administration Group.

New Special Enrollment Confirmation Process

Posted on March 3, 2016 by tomdaly

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Due to concerns about whether current federal Health Insurance Marketplace rules and procedures are sufficient to ensure that only those who are eligible enroll through special enrollment periods, the Centers for Medicare & Medicaid Services (CMS) has created a new verification process for individuals to apply.

How Special Enrollment Confirmation Works
Beginning in the next several months, all consumers who enroll or change plans using a special enrollment period for any of the following triggering events will be directed to submit documentation to verify their eligibility:

Loss of minimum essential coverage;
Permanent move;
Birth, adoption, placement for adoption, placement for foster care or child support or other court order; or
Marriage.

CMS will provide consumers with lists of qualifying documents, such as a birth or marriage certificate. Consumers will be able to upload documents to their HealthCare.gov accounts or mail them in.

For more information about implementation of the new process, please review the CMS announcement and Fact Sheet.

Indicator Codes for Employee Offer and Coverage (Form 1095-C, Line 14)

Posted on December 30, 2015 by tomdaly

In case you don’t recognize the format, this is an excerpt from an IRS favorite: Instructions for Forms 1094-C and 1095-C.

Code Series 1— Offer of Coverage. The Code Series 1 indicator codes specify the type of coverage, if any, offered to an employee, the employee’s spouse, and the employee’s dependents. The term “dependent” has the specific meaning set forth in the Definitions section of these instructions. In addition, for this purpose an offer of coverage is treated as made to an employee’s dependents only if the offer of coverage is made to an unlimited number of dependents regardless of the actual number of dependents, if any, an employee has during any particular calendar month. An offer of COBRA continuation coverage that is made to a former employee upon termination of employment should not be reported as an offer of coverage on line 14. For a terminated employee, code 1H (No offer of coverage) should be entered for any month for which the offer of COBRA continuation coverage applies. An offer of COBRA continuation coverage that is made to an active employee (for instance, an offer of COBRA continuation coverage that is made due to a reduction in the employee’s hours that resulted in the employee no longer being eligible for coverage under a plan) is reported in the same manner and using the same code as an offer of that type of coverage to any other active employee. If the type of coverage, if any, offered to an employee was the same for all 12 months in the calendar year, enter the Code Series 1 indicator code corresponding to the type of coverage offered in the “All 12 Months” box or in each of the 12 boxes for the calendar months.

1A. Qualifying Offer: Minimum essential coverage providing minimum value offered to full-time employee with employee contribution for self-only coverage equal to or less than 9.5% mainland single federal poverty line and at least minimum essential coverage offered to spouse and dependent(s).

This code may be used to report for specific months for which a Qualifying Offer was made, even if the employee did not receive a Qualifying Offer for all 12 months of the calendar year. However, an employer may not use the Alternative Furnishing Method for an employee who did not receive a Qualifying Offer for all 12 calendar months (except in cases in which the employer is eligible for and reports using the Alternative Furnishing Method for 2015 Qualifying Offer Method Transition Relief as described in these instructions).
1B. Minimum essential coverage providing minimum value offered to employee only.
1C. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) (not spouse).
1D. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to spouse (not dependent(s)).
1E. Minimum essential coverage providing minimum value offered to employee and at least minimum essential coverage offered to dependent(s) and spouse.
1F. Minimum essential coverage NOT providing minimum value offered to employee; employee and spouse or dependent(s); or employee, spouse and dependents.
1G. Offer of coverage to employee who was not a full-time employee for any month of the calendar year (which may include one or more months in which the individual was not an employee) and who enrolled in self-insured coverage for one or more months of the calendar year.
1H. No offer of coverage (employee not offered any health coverage or employee offered coverage that is not minimum essential coverage, which may include one or more months in which the individual was not an employee).
1I. Qualifying Offer Transition Relief 2015: Employee (and spouse or dependents) received no offer of coverage; received an offer that is not a qualifying offer; or received a qualifying offer for less than 12 months.

2015 ACA Reporting is Delayed

Posted on December 29, 2015 by tomdaly

In Notice 2016-4, the IRS has extended the due dates for certain 2015 Affordable Care Act information reporting requirements.

Specifically, the Notice extends:

the due date for furnishing to individuals the 2015 Form 1095-B and Form 1095-C from February 1, 2016, to March 31, 2016, and
the due date for filing with the IRS the 2015 Form 1094-B, Form 1094-C and Form 1095-C from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016 if filing electronically.

For detailed information about these Forms, please see our earlier article.

In the Notice, the IRS also grants special relief to certain employees and related individuals who receive their Form 1095-C or Form 1095-B, as applicable, after they have filed their returns:

For 2015 only, individuals who rely upon other information received from employers about their offers of coverage for purposes of determining eligibility for the premium tax credit when filing their income tax returns will NOT be required to amend their returns once they receive their Forms 1095-C or any corrected Forms 1095-C.
For 2015 only, individuals who rely upon other information received from their coverage providers about their coverage for purposes of filing their returns will NOT be required to amend their returns once they receive the Form 1095-B or Form 1095-C or any corrections.

Thus, generally, employers should not be concerned that furnishing these Forms on a delayed basis in accordance with the Notice will force employees to file amended 2015 income tax returns.

Finally, the extensions do not require the submission of any request or other documentation to the IRS and have no effect on information reporting provisions for other years.

See more at National Review

10 Things to Buy with $695

Posted on October 30, 2015 by tomdaly

(Instead of paying the federal penalty in 2016 for having no health insurance)

About 7 years and 2 months of Netflix
330 Sucre signature macaroons
A 500-mile Uber ride
2 Dat Dog beef or pork dogs a week for the next year
A Tropical Isle Hand Grenade for you and 90 of your closest friends
1478 rolls of toilet paper
Over 100 burgers from Five Guys plus all the peanuts you can eat
2 Saints tickets for this Sunday and about 11 overpriced beers in the Superdome
388 Fiery Doritos Locos Tacos from Taco Bell
Approximately 115 Old Fashioneds at Cure during happy hour

…or you could always go for a backyard roller coaster.

Section 4980H Safe Harbor Codes and Other Relief for Employers

Posted on September 21, 2015 by tomdaly

Here is my favorite section of the Instructions for Forms 1094-C and 1095-C. I thought it was worth sharing. . .

An employer enters the applicable Code Series 2 indicator code, if any, on line 16 to report for one or more months of the calendar year that one of the following situations applied to the employee: the employee was not employed or was not a full-time employee; the employee enrolled in the minimum essential coverage offered; the employee was in a Limited Non-Assessment Period with respect to section 4980H(b); non-calendar year transition relief applied to the employee; the employer met one of the section 4980H affordability safe harbors with respect to this employee; or the employer was eligible for multiemployer interim rule relief for this employee. In some circumstances more than one situation could apply to the same employee in the same month. For example, an employee could be enrolled in health coverage for a particular month during which he or she is not a full-time employee. However, only one code may be used for a particular calendar month. For any month in which an employee enrolled in minimum essential coverage, indicator code 2C reporting enrollment is used instead of any other indicator code that could also apply (but see the exception to this rule below, regarding the multiemployer interim rule relief). For an employee who did not enroll in health coverage, there are some specific ordering rules for which code to use. See the descriptions of the codes.

2A. Employee not employed during the month. Enter code 2A if the employee was not employed on any day of the calendar month. Do not use code 2A for a month if the individual was an employee of the employer on any day of the calendar month. Do not use code 2A for the month during which an employee terminates employment with the employer.
2B. Employee not a full-time employee. Enter code 2B if the employee is not a full-time employee for the month and did not enroll in minimum essential coverage, if offered for the month. Enter code 2B also if the employee is a full-time employee for the month and whose offer of coverage (or coverage if the employee was enrolled) ended before the last day of the month solely because the employee terminated employment during the month (so that the offer of coverage or coverage would have continued if the employee had not terminated employment during the month). Also use this code for January 2015 if the employee was offered health coverage no later than the first day of the first payroll period that begins in January 2015 and the coverage offered was affordable for purposes of the employer shared responsibility provisions under section 4980H and provided minimum value.
2C. Employee enrolled in coverage offered. Enter code 2C for any month in which the employee enrolled in health coverage offered by the employer for each day of the month, regardless of whether any other code in Code Series 2 (other than code 2E) might also apply (for example, the code for a section 4980H affordability safe harbor). Do not enter 2C in line 16 if code 1G is entered in the All 12 Months Box in line 14 because the employee was not a full-time employee for any months of the calendar year. Do not enter code 2C in line 16 for any month in which a terminated employee is enrolled in COBRA continuation coverage (enter code 2A).
2D. Employee in a section 4980H(b) Limited Non-Assessment Period. Enter code 2D for any month during which an employee is in a Limited Non-Assessment Period for section 4980H(b).If an employee is in an initial measurement period, enter code 2D (employee in a section 4980H(b) Limited Non-Assessment Period) for the month, and not code 2B (employee not a full-time employee). For an employee in a section 4980H(b) Limited Non-Assessment Period for whom the employer is also eligible for the multiemployer interim rule relief for the month, enter code 2E (multiemployer interim rule relief) and not code 2D (employee in a Limited Non-Assessment Period).
2E. Multiemployer interim rule relief. Enter code 2E for any month for which the multiemployer arrangement interim guidance applies for that employee, regardless of whether any other code in Code Series 2 (including code 2C) might also apply. This relief is described under Offer of Health Coverage in the Definitions section of these instructions.
2F. Section 4980H affordability Form W-2 safe harbor. Enter code 2F if the employer used the section 4980H Form W-2 safe harbor to determine affordability for purposes of section 4980H(b) for this employee for the year. If an employer uses this safe harbor for an employee, it must be used for all months of the calendar year for which the employee is offered health coverage.
2G. Section 4980H affordability federal poverty line safe harbor. Enter code 2G if the employer used the section 4980H federal poverty line safe harbor to determine affordability for purposes of section 4980H(b) for this employee for any month(s).
2H. Section 4980H affordability rate of pay safe harbor. Enter code 2H if the employer used the section 4980H rate of pay safe harbor to determine affordability for purposes of section 4980H(b) for this employee for any month(s).

Note.

Codes 2F through 2H: Although employers may use the section 4980H affordability safe harbors to determine affordability for purposes of the multiemployer arrangement interim guidance, an employer eligible for the relief provided in the multiemployer arrangement interim guidance for a month for an employee should enter code 2E (multiemployer interim rule relief), and not a code for the section 4980H affordability safe harbors (codes 2F, 2G, or 2H).
2I. Non-calendar year transition relief applies to this employee. Enter code 2I if non-calendar year transition relief for section 4980H(b) applies to this employee for the month. See the instructions later under Section 4980H Transition Relief for 2015 and 2015 Section 4980H(b) Transition Relief for Employers with Non-Calendar Year Plans (Form 1095-C, line 16, code 2I), for a description of this relief.

Note.

References to 9.5% in the affordability safe harbors and alternative reporting methods may be subject to change if future IRS guidance provides that the percentage is indexed in the same manner as that percentage is indexed for purposes of applying the affordability thresholds under Internal Revenue Code section 36B (the premium tax credit). In general this should not affect reporting for 2015, but taxpayers may visit IRS.gov for any related updates.

2015 Forms 1094-B, 1095-B, 1094-C, and 1095-C

Posted on September 18, 2015 by tomdaly

The Internal Revenue Service (IRS) has released finalized forms and instructions for 2015 to help employers prepare for compliance with the new information reporting provisions under the Affordable Care Act (ACA). Employers are required to report for the first time in early 2016 for calendar year 2015. These forms will be due out by the end of January.

Who is Required to Report
As a reminder, Forms 1094-B and 1095-B will be used by insurers, self-insuring employers, and other parties that provide minimum essential health coverage (regardless of size, except for large self-insuring employers) to report information on this coverage to the IRS and to covered individuals.

Large employers (generally those with 50 or more full-time employees, including full-time equivalents or FTEs) will use Forms 1094-C and 1095-C to report information to the IRS and to their employees about their compliance with the employer shared responsibility provisions (“pay or play”) and the health care coverage they have offered.

Note: Employers subject to both reporting provisions (generally self-insured employers with 50 or more full-time employees, including FTEs) will satisfy their reporting obligations using Forms 1094-C and 1095-C. Form 1095-C includes separate sections for reporting under each provision.

2015 Forms and Instructions
Final versions of the 2014 forms were previously released for those employers that chose to voluntarily comply for the 2014 calendar year. The following forms and instructions are now available for 2015:

Forms 1095-B and 1095-C must be electronically filed if the employer is required to file at least 250 of the specific form.

For More Information
Additional details on the information reporting requirements for providers of minimum essential coverage, including self-insuring employers, are available in IRS Questions and Answers. More information about the information reporting requirements for large employers subject to “pay or play” is available in separate IRS Questions and Answers.

Changing, updating, or cancelling your Marketplace plan

Posted on August 12, 2015 by tomdaly

If you have a 2015 plan through the Health Insurance Marketplace, you have limited opportunities to make changes outside the Open Enrollment Period.

The deadline for changing or enrolling in a 2015 plan was February 15, 2015.

Changing 2015 plans: With Special Enrollment Period only

You can change Marketplace insurance plans outside Open Enrollment only if you qualify for a Special Enrollment Period due to a life change like getting married, having a baby, or losing other coverage.

Find out if you’re eligible for a Special Enrollment Period.

Updating your 2015 coverage: All year when you have life changes

You should update your 2015 Marketplace information all year by reporting any changes to your income and household.

Some changes – like having a baby, adopting a child, getting married, or losing other coverage – will qualify you for a Special Enrollment Period.
If you report an income change but don’t qualify for a Special Enrollment Period, you can adjust the amount of premium tax credit you take in advance every month. This will make sure your savings stay right for your income level all year.
- If your income goes up, you may be taking more advance payments of your premium tax credit than you qualify for. If you don’t report the change, you may have to pay money back on your next federal tax return.
- If your income goes down, you may be able to take more advance payments of your premium tax credit, lowering what you have to pay for premiums each month. You also could qualify for free or very-low-cost coverage through Medicaid or the Children’s Health Insurance Program (CHIP) instead of a Marketplace plan.

Learn how to update your coverage information for 2015.

Cancelling your 2015 plan

If you get other health coverage during the year or for some other reason need to cancel your 2015 health plan, you can do that any time. You can cancel coverage for everyone in your household or just certain people.

Learn how to cancel your 2015 coverage.

Cadillac Tax Explained

Posted on July 7, 2015 by tomdaly

The Cadillac Tax is the next BIG provision of the Affordable Care Act to begin in 2018. That may seem like an eternity from now. But, given the potential impact to employer groups, I thought it was at least worth a closer review. Below is the most digestible information I could find (from our good friends at Cigna):

Overview

Scheduled to take effect in 2018, the “Cadillac Tax” is a 40% non-deductible excise tax on employer-sponsored health coverage that provides high-cost benefits.

On February 23, 2015, the Internal Revenue Service (IRS) issued a notice covering a number of issues concerning the Cadillac Tax, and requested comments on the possible approaches that could ultimately be incorporated into proposed regulations. No regulations have been issued to date.

	CADILLAC TAX
What it is/fee duration	Permanent, non-deductible, annual tax beginning in 2018 on high-cost employer-sponsored health coverage.
Purposes	Reduce tax preferred treatment of employer provided health care Reduce excess health care spending by employees and employers Help finance the expansion of health coverage under the Patient Protection and Affordable Care Act (PPACA)
Amount	The tax is 40% of the cost of health coverage that exceeds predetermined threshold amounts. Cost of coverage includes the total contributions paid by both the employer and employees, but not cost-sharing amounts such as deductibles, coinsurance and copays when care is received. For planning purposes, the thresholds for high-cost plans are currently $10,200 for individual coverage, and $27,500 for family coverage. These thresholds will be updated for 2018 when final regulations are issued and thereafter indexed for inflation in future years. The thresholds will also be increased: If the majority of covered employees are engaged in specified high-risk professions such as law enforcement and construction, and For group demographics including age and gender. For pre-65 retirees and individuals in high-risk professions, the threshold amounts are currently $11,850 for individual coverage and $30,950 for family coverage.
Who calculates and pays	Insured: Employers calculate and insurers pay Self-funded: Employers calculate and pay
How a group health plan’s cost is determined	The tax is based on the total cost of each employee’s coverage above the threshold amount. The cost includes contributions toward the cost of coverage made by employers and employees. The statute states that costs of coverage will be calculated under rules similar to the rules for calculating COBRA premium.
How the tax will be paid	Forms and instructions for paying the tax are not yet available.
Tax implications	Cadillac Tax payments are not deductible for federal tax purposes.
Applicable types of coverage	Insured and self-insured group health plans (including behavioral, and prescription drug coverage) Wellness programs that are group health plans Health Flexible Spending Accounts (FSAs) Health Savings Accounts (HSAs)(Employer pre-tax contributions only)* Health Reimbursement Accounts (HRAs)* Archer Medical Savings Accounts (MSAs) (Employer pre-tax contributions only)* On-site medical clinics providing more than de minimis care* Executive Physical Programs* Pre-tax coverage for a specified disease or illness Hospital indemnity or other fixed indemnity insurance Federal/State/Local government-sponsored plans for its employees Retiree coverage Multi-employer (Taft-Hartley) plans
Excluded types of coverage	U.S.-issued expatriate plans for most categories of expatriates Coverage for accident only, or disability income insurance, or any combination thereof Supplemental liability insurance Liability insurance, including general liability insurance and automobile liability insurance Worker’s compensation or similar insurance Automobile medical payment insurance Credit-only insurance Other insurance coverage as specified in regulations under which benefits for medical care are secondary or incidental to other insurance benefits Long Term Care Standalone dental and vision* Coverage for the military sponsored by federal, state or local governments* Employee Assistance Programs* Employee After-Tax Contributions to HSAs and MSAs* Coverage for a specified disease or illness and hospital indemnity or other fixed indemnity insurance if payment is not excluded from gross income

*As indicated by IRS notice issued on February 23, 2015 and subject to future regulatory clarification.

How it works: Examples based on current threshold amounts

Self-only coverage
A $12,000 individual plan would pay an excise tax of $720 per covered employee:
$12,000 – $10,200 = $1,800 above the $10,200 threshold
$1,800 x 40% = $720

Family coverage
A $32,000 family plan would pay an excise tax of $1,800 per covered employee:
$32,000 – $27,500 = $4,500 above the $27,500 threshold
$4,500 x 40% = $1,800

These charts show how the tax increases as the plan’s cost increases.

Self-only coverage

Plan Cost	$11,000	$12,000	$13,000	$14,000	$15,000
Tax	$320	$720	$1,120	$1,520	$1,920

Family coverage

Plan Cost	$28,000	$30,000	$32,000	$34,000	$36,000
Tax	$200	$1,000	$1,800	$2,600	$3,400

Marriage and the Affordable Care Act

Posted on June 29, 2015 by tomdaly

Last week’s Supreme Court decisions made it a historic week for our great Country. The latest challenge to State-based subsidies in the Affordable Care Act was defeated AND the Court affirmed that the Constitution guarantees a right to same-sex marriage. That is some pretty significant ground to cover, and whether you are for or against these rulings, you cannot deny that meaningful change has come.

While change has made many things much easier (see – Ruling changes financial plans for same-sex couples), there are a few idiosyncrasies to be aware of, relative to the ACA and tying the knot:

Eligibility for spouse’s group plan – If your spouse has access to affordable, minimum-value health coverage through his/her employer, you are NOT eligible for a subsidy through the Exchange regardless of income. This means even if you already have a subsidized health plan, when you marry someone who is able to add you to his/her policy as a spouse, you lose your subsidy. Some call this the family/marriage “glitch”. It would be nice to see this fixed at some point!
Combined income means revised subsidy determination – When individuals get married, their definition of affordability under the law changes and so does their subsidy determination. Unfortunately, married people do not get as much help as singles at the lower income levels. To use an example, Bob and Steve are both 40 years old and both earn $25,000/year. Unmarried, they each qualify for a subsidy of $153/month (or $306/month combined). That combined subsidy reduces to $192 when the couple gets married. That is almost a 40% reduction in their subsidy. The impact is even more profound when additional dependents are in the mix, when incomes are lower AND when ages are higher.
Qualifying life event – Do not forget that marriage is one of the triggering events for a Special Enrollment Period. This is a time outside of the open enrollment period during which you and your family have a right to sign up for health coverage. In the Marketplace, you qualify for a special enrollment period 60 days following certain life events that involve a change in family status (for example, marriage or birth of a child) or loss of other health coverage. Job-based plans must provide a special enrollment period of 30 days.

These laws were written with the intention of making life easier/better for all. But, we are responsible to know the rules and when/how they apply to us. If you need any help navigating these waters, don’t ever hesitate to ask.