Wakely reviewed the potential impacts of the proposed Marketplace Integrity and Affordability Rule, with a specific focus on the proposed premium payment withhold requirement, on the Affordable Care Act compliant individual health insurance market (ACA individual market). This provision would withhold a portion of advanced premium tax credits (APTCs) for enrollees that do not verify their incomes (i.e., are auto-enrolled) and also have $0 dollar net premiums to instead have a small ($5) charge per month until they actively confirm their information.
While the proposed rule’s impact analysis found negligible effects of this provision in a scenario in which enhanced premium tax credits (ePTCs) expire in 2026, we analyzed impacts if this proposal was finalized and ePTCs were available.
Overall, we estimate that in this scenario, enrollment could reduce 0.2% to 6.1% and market average premiums could increase between 0.2% and 3.7% for states which the provisions are applicable in 2026.
