Consumers who are enrolled in assisted qualified health plans (aQHP) must reconcile the advance premium tax credit (APTC) they’ve received during any prior year on their following year’s tax return in order to continue receiving the premium tax credit in advance for the next year.
When the renewal batch is run each year, the data for each household is compared to IRS data to confirm the household reconciled any prior year tax year. The IRS data provides a Failure to Reconcile (FTR) flag on any household for which the IRS has no record of tax credit reconciliation. When the FTR flag is present, the household is renewed without assistance. However, during open enrollment, consumers have the option of attesting to tax filing and tax credit reconciliation. Once the attestation is complete, if the household is otherwise eligible, APTC is restored.
Once open enrollment is over, the attestation option is no longer available. If the consumer did not come in during open enrollment to attest, then the only way to restore APTC is through one of two processes, described below. Please do NOT escalate these cases; APTC cannot be manually restored on FTR cases until the flag is lifted in the IRS data. Even if the consumer brings you a box of tax returns evidencing their compliance with APTC reconciliation, Maryland Health Connection can’t restore APTC until the FTR flag is lifted in the IRS data.
After open enrollment, APTC can be restored by:
Report a change and submit a new application. There may or may not be an actual change, but you must report a change so that the electronic resources get pinged. When the consumer reports a change, as long as they have visited both the tax filing and income screens, the online IRS data will be checked. If the flag is lifted, and the consumer is otherwise eligible, APTC will be displayed on the eligibility determination page. Reporting a simple change of address won’t work. The consumer should select the amount of APTC desired, and also may choose a different plan. A Special Enrollment Period (SEP) opens when a consumer goes from $0 APTC to any dollar APTC. The new APTC will be effective the first of the following month. However, if he also makes a plan change, the plan change will follow the 15th-of-the-month rule. For example, if the consumer comes in to report a change Jan. 20 the APTC is restored effective Feb.1. If the consumer also decides to change plans, the new plan is effective March 1.
The consumer can report a change as often as he likes, but we do not recommend doing it more than once a week.
- Monthly bulk data check — we receive a monthly bulk data file from the IRS on the last Sunday of each month. Within a day or two of receiving it, we will check all active uQHP consumers against this data to see if the flag is lifted. If the flag is lifted, eligibility will be redetermined and a new 1303 (eligibility determination notice) will be sent. However, with this process we cannot automatically send the APTC over to the carrier. We will leave the app in a determined status. Once the consumer receives the notice, the consumer should return to his account, pick up the determined app, and proceed to APTC selection and shopping to complete aQHP enrollment. Then, the new enrollment information will be sent to the carrier and will be effective the first of the following month (APTC) or follow the 15th-of-the-month rule (new QHP).
In neither instance may APTC be applied retroactively, however the consumer may be able to claim any APTC not received in the first months of the year when he files his tax return next year.
Important note: both of these processes are only available to the consumer who stays enrolled in an uQHP and pays the full premium. If a consumer can’t afford the full premium and is terminated for non-payment or decides to disenroll, we will not check him against the monthly bulk data, nor can he get APTC restored through change reporting (unless he happens to qualify for another SEP).