Centers for Medicare and MedicaidServices (Photo: CMS)

The Affordable Care Act public exchange system is making a change thatcould help some people avoid tax nightmares but cause some otherpeople to suffer a sudden, unexpected loss of ACA exchange planhealth coverage.

The public exchange programs will be automatically ending theexchange plan coverage of many exchange plan users who appear tohave Medicare coverage.

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Officials from the Centers for Medicare and Medicaid Services(CMS) talk about the new, automatic expulsion effort in a guide tothe “periodic data matching” effort that was releasedWednesday.

The Background

The ACA exchange plan program gives low-income andmoderate-income people a way to use ACA premium tax creditsubsidies to help pay for coverage.

Medicare is a federal health insurance program that servespeople ages 65 and older, many younger people who qualify forSocial Security Disability Insurance benefits, and people who needkidney dialysis.

Under federal law, people are not supposed to use ACA premiumtax credit subsidies and have Medicare coverage at the sametime. ”Double dippers” may have to return any ACA premiumtax credits they received while on Medicare, when they file theirfederal income tax returns.

CMS and the exchange programs have been trying tolocate ACA exchange-Medicare double dippers every year since2015.

The 2019 Change

The 2019Medicare periodic data matching will probably be different, becauseCMS now has better data matching information technology, officialssay in the new Medicare data matching program guide.

The new technology  “allows the exchange to take actionand end a consumer's [ACA subsidies] if they're found tobe dually enrolled in Medicare and an exchange health plan,”officials say. “Beginning in 2019, the exchange will now also endexchange health plan coverage for consumers who permit the exchangeto take this action if they're found to be dually enrolled at alater date.”

Nuts and Bolts for Agents

Here are some 2019 Medicare datamatching program details that could be of interest to producers whoare trying to help consumers understand data matching programnotices, or resolve coverage cancellation problems.

In some cases, an ACA exchange willcancel a suspected double dipper's exchange plan coverage alongwith the subsidy money.

The exchange may cancel asuspected double dipper's exchange plan coverage automatically ifthe suspected double dipper gave the exchange permission to do so,by saying “yes” to a question in the exchange application.

An affected consumer will have 30days from the date the notice is sent to respond to the notice.

If a consumer has given an exchangepermission to cancel double dipper exchange plan coverageautomatically, then the exchange can cancel the suspected doubledipper's ACA subsidies, and health coverage, after the 30-dayresponse window has ended.

Consumers may give an exchange permission to end their exchangeplan health coverage, as well as their ACA subsidy support,automatically, if the exchange discovers that the consumers areMedicare-exchange plan double dippers. The question authorizingautomatic coverage terminations is in the exchange programapplication.

Exchanges may send Medicare periodicdata matching notices throughout the year.

Consumers who believe that they arestill eligible to keep their coverage in place can file appeals. Aconsumer must send the appeal to the U.S. Department of Health andHuman Services' Marketplace Appeals Center. “Consumerswill receive instructions on how to appeal the exchange'sdetermination in the final [periodic data matching] noticeoutlining the action that the exchange will be taking,” officialssay in the data matching program guide.

Resources

A copy of the Medicare data matching guidance is available here.

Read more: 

• Medicare and HSA eligibility: Understanding therules
• Opposing Trump actions bring more uncertainty toACA marketplaces