CMS has announced that in light of persistent problems individuals have had enrolling in qualified health plans (QHPs) through some state-run Marketplaces, it will now allow individuals to access premium tax credits and cost-sharing reductions on a retroactive basis in certain circumstances. Specifically, in guidance dated February 27, 2014, CMS states that if a Marketplace was unable to provide timely eligibility determinations during the initial open enrollment period for the 2014 coverage year, it may be considered an “exceptional circumstance” for individuals who were unable to enroll in a QHP as a result. In such cases, CMS will make available advance payments of the premium tax credit and advance payments of cost-sharing reductions on a retroactive basis once the Marketplace has determined that the individual is eligible for such assistance and the individual has enrolled in a QHP through the Marketplace. Notably, CMS also provides an individual in this exceptional circumstance who is enrolled in a QHP offered outside of the Marketplace when he or she receives a determination of eligibility will be treated as having been enrolled through the Marketplace since the initial enrollment date.
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