The enrollment gains made from the expansions of cost-saving subsidies in the American Rescue Plan Act (ARPA) are at risk, as the enhanced subsidies that pushed enrollment to 14.5 million, are set to expire at the end of the year. The American Rescue Plan not only increased the premium subsidy amounts for consumers with incomes below 400% (approximately $35,000 annually) of the Federal Poverty Level (FPL), ARPA also allowed consumers with income above 400% of FPL to access a premium subsidy for the first time, allowing more than one million consumers to access money-saving tax credits for the first time. As Congress continues to work towards a resolution of whether to extend these subsidies, open enrollment gets closer every day.  

The technology challenges that come with a late decision on whether the subsidies will be extended, altered in some way, or be allowed to expire are forcing every health insurance exchange in the country to have to reconfigure eligibility logic to accommodate the outcome in a short timeline, right before renewals. And while state-based exchanges are in a better position to implement these changes in a short period of time,, which supports 33 states, is likely to experience more challenges.  

So, while technically the rule changes can be solved for, the arguably larger issue is how all of this will impact consumers and ultimately enrollment for 2023. Last year, exchanges reached record enrollment numbers, but the question remains, if the subsidies expire, will consumers keep their coverage. It has been estimated that coverage would become unaffordable for millions without the enhanced subsidies. It’s also probably fair to say that most of these consumers aren’t following policy changes, so we can expect there to be a lot of confusion in the marketplace come November, which will also impact enrollment. Many state-based exchanges are currently putting communication plans in place that would cover a variety of scenarios to help lesson confusion and help people understand their current options.  

However, as Heather Korbulic, Senior Policy and Strategy Lead at GetInsured, noted in a recent interview with Modern Healthcare, “Unless Congress takes action in the next month, we’re gonna have to start sending notices,” Heather Korbulic said. “If they choose to take action after those notices go out, the damage will already be done. People will already be confused, and it’s going to be really hard to put the cat back in the bag.”