Let's wait and see what the repayment cap is for those who wind up above the 400% level and who shouldn't have gotten a subsidy at all.
Still, this could turn into another point to be artfully used. Manage taxable withdrawals to get max ACA subsidies, then take out what you really need the following year and fail to qualify for the subsidies, and owe a repayment--but since it is only a partial repayment, it still makes sense to do it.
I was hoping to avoid doing any "forecasting" at all, and just take the subsidy after the fact once I knew what my income had been. If the article is right and payments are to be made directly to insurance companies, that won't work.
7 1/2 months from full implementation and the info is still coming out in press releases and papers by private entities. The folks responsible for getting this rollout done right and publicizing it appear to be incompetent. This is not a partisan issue: Even congressmen who wrote the law and strongly favor it are
fed up with the way this implementation is being handled. It is a mess.