Advanced premium tax credits - filing guidance

[LOGO] KAY IVEY GOVERNOR MARK FOWLER ACTING COMMISSIONER STATE OF ALABAMA DEPARTMENT OF INSURANCE 201 MONROE STREET, SUITE 502 POST OFFICE BOX 303351 MONTGOMERY, ALABAMA 36130-3351 TELEPHONE: (334) 269-3550 FACSIMILE: (334) 241-4192 INTERNET: www.aldoi.gov DEPUTY COMMISSIONER JIMMY W. GUNN CHIEF EXAMINER SHEILA TRAVIS STATE FIRE MARSHAL SCOTT F. PILGREEN GENERAL COUNSEL REYN NORMAN # BULLETIN NO. 2022-04 TO: Health insurance issuers, health care service plans, health maintenance organizations, or other entities acting under the Affordable Care Act FROM: Mark Fowler Acting Commissioner of Insurance DATE: July 14, 2022 RE: Advanced premium tax credits – filing guidance EFFECTIVE: Immediate In March 2021, Congress passed the American Rescue Plan Act (ARPA), P.L. 117-7, 135 Stat. 4, which temporarily made coverage on the Affordable Care Act (ACA) marketplaces more affordable by increasing and expanding Advanced Premium Tax Credits (APTC), thereby lowering the amount consumers must contribute to their Individual Qualified Health Plan (QHP) premiums. However, under current law the enhanced premium tax credits expire at the end of 2022. # Filing guidance regarding initial rates Carriers submitting 2023 Individual QHP rate filings should calculate rates under current law, meaning ARPA expanded APTC subsidies will expire at the end of this year. If there are no legislative changes at the federal level regarding APTC subsidies during the rate review period, these are the rates that carriers intend to be implemented upon approval. # Filing guidance regarding revised rates Carriers who intend to revise their rates if legislative changes occur at the federal level regarding APTC subsidies should be prepared to submit an alternative rate filing if time allows during the rate review period. This alternative filing will only be implemented if those legislative changes do occur and the rates are approved. Carriers are required to also provide the following items for review: - The change in rates due to the extension of ARPA by plan - A crosswalk of all the assumption changes due to the extension of ARPA along with support for each change Celebrating 125 Years of Insurance Regulation 1897 - 2022 Bulletin No. 2022-04 July 14, 2022 Page 2 - A description on where the changes are incorporated into the filing (URRT and Actuarial Memorandum) - The impact on premium rates of all the assumption changes due to the extension of ARPA If you have any questions, please contact Jennifer Li, Senior Life and Health Actuary at Jennifer.Li@insurance.alabama.gov. MF/JFM/bc