Comments submitted on HHS Notice of Benefit and Payment Parameters for 2021

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Editor's note:

This analysis is part of the USC-Brookings Schaeffer Initiative for Health Policy, which is a partnership between Economic Studies at Brookings and the University of Southern California Schaeffer Center for Health Policy & Economics. The Initiative aims to inform the national health care debate with rigorous, evidence-based analysis leading to practical recommendations using the collaborative strengths of USC and Brookings. 

USC-Brookings Schaeffer Initiative experts provided comments to HHS Secretary Azar on the proposed rule, HHS Notice of Benefit and Payment Parameters for 2021 (CMSD-9916-P).

The Department of Health and Human Services (HHS) had proposed a change to rules regarding the provision of  advance premium tax credits (APTC) for individuals receiving financial assistance under the ACA. This would result in a reduction in the amount of APTC an individual received if the financial calculation indicated that they would receive enough money to cover the entire plan premium. Young and Levitis argue that the agency’s attempts to change the APTC are both unlawful and exceed their authority. Read the full comment here.