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Notices Mailed for Open Enrollment 2021
In addition to the Marketplace Open Enrollment Notices (MOENs) mailed in September 2020, the Marketplace mailed in October 2020 a paper supplemental notice to tax filers who according to IRS data had not filed an income tax return for 2019 or have filed but not reconciled their 2019 APTC. This supplemental notice warned tax filers that they are at risk for losing APTC in 2021 if they do not file a 2019 tax return and reconcile 2019 APTC immediately. After filing and reconciling their taxes, consumers are encouraged to answer the attestation question on the Marketplace application as soon as possible. (Note: This supplemental notice is not an eligibility determination.)
Because of the COVID-19 pandemic, the IRS has experienced delays processing tax returns. It is especially important this year for consumers whose tax filers have filed and reconciled for 2019 to attest that they have done so on their 2021 application by checking the box that says “Yes, I reconciled premium tax credits for past years.”
Consumers who have not yet filed and reconciled for 2019 should do so immediately.
- After filing an income tax return and reconciling for 2019, enrollees should return to the Marketplace, create or update a 2021 application and attest on the application that their tax filer has filed a tax return and reconciled all past APTC.
- In mid-December 2020, the Marketplace will do a final check of IRS data for Failure to File and Reconcile (FTR) enrollees who did not return to the Marketplace, in order to retain APTC for those who filed and reconciled since the original IRS data check in September 2020.
- Enrollees whose APTC is discontinued beginning January 1, 2021 will receive an updated eligibility determination notice (EDN) informing them of this change. These enrollees can still take additional steps to restore their APTC. As long as the enrollee remains enrolled in their Marketplace plan, he or she may return to the Marketplace application, report a life change, attest to filing and reconciling, receive a new eligibility determination, select a plan, and receive APTC prospectively, following the 15th of the month coverage effective date rules. Additionally, enrollees can appeal the Marketplace’s determination to discontinue APTC by following the appeals process communicated in their updated EDN.
For more information on how to file and reconcile, please visit:
https://www.irs.gov/affordable-care-act/individuals-and-families/premium-tax-credit-claiming-the-credit-and-reconciling-advance-credit-payments.
More information on the Failure to File and Reconcile (FTR) process can be found here: https://marketplace.cms.gov/technical-assistance-resources/overview-of-ftr-recheck-process.pdf
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