ACA and predicting income (plus avoiding DMI)

Interesting. This is one place I don't gamble since I consider the stakes too high. I would worry I'd somehow become ineligible for ACA if I constantly way under-reported my income which would radically change or end my ER.
The biggest concern if you under report income is being placed into Medicaid. I've been in the ACA for 7 years now, and one year reported my income too low , and was placed into Medicaid. That was a big mistake, because all our doctors didn't take Medicaid that year. I make sure now to stay around the $35-$38K income range.
 
The Premium Tax Credits are permanent and will continue indefinitely. Any change requires congressional action. The Enhanced PTC, part of the ARPA of 2021, are authorized through tax year 2025. After that they expire unless extended by congress.
Right. That's explained well on this web page, which also offers you an estimate of how your cost might change without the Enhanced PTC. I plugged in my numbers and was surprised that my cost would not increase that much.

I believe the repayment limitations would bite it, too, if the ARPA provisions are not extended.
 
The biggest concern if you under report income is being placed into Medicaid. I've been in the ACA for 7 years now, and one year reported my income too low , and was placed into Medicaid. That was a big mistake, because all our doctors didn't take Medicaid that year. I make sure now to stay around the $35-$38K income range.
Yup, always kept my MAGI between 125% and 150% of FPL.
 
The biggest concern if you under report income is being placed into Medicaid. I've been in the ACA for 7 years now, and one year reported my income too low , and was placed into Medicaid. That was a big mistake, because all our doctors didn't take Medicaid that year. I make sure now to stay around the $35-$38K income range.
After being on ACA for years I decided to go on Medicaid because the amount I would have to take from my IRA and pay a penalty on in order to hit 100% FPL to qualify for ACA was more than I needed for living expenses. I didn't want to pay the penalty on withdrawals any more than I needed to. Being on Medicaid(or my states equivalent) hasn't been an issue.
 
I'm enrolling for our second year in the ACA health insurance marketplace, after this first year where we had some severance income, meaning 2025 will be the first year that our income will be primarily if not almost entirely investment income. As you know, you have to provide an educated guess on your income in order to determine the premium tax credit, which I can do based on my strategy for generating cash for living. My broker tells me I can shoot low, even very low, on the income and the difference will be worked out when I do our tax return in early 2026 -- fine, I'm totally willing to do that even if I must pay a lot at that time -- and that he has heard of some clients not having to repay the full PTC difference at tax time (here in Illinois). That suggests that the gamble to shoot low on the income prediction could pay off a little. Sounds ridiculous, but OK, such is bureaucracy. And I've read up on DMI, data match inconsistency, so I know if I'm predicting less than 50% lower than the previous year's income, I'm OK -- or in any case, so far the Eligibility Letter is not saying I have to provide documentation to account for any income discrepancy. (And I also know that if our income drastically veers from the prediction especially on the high side, you gotta tell 'em.)

What do you think? Have you ever simply aimed low on predicted income like this?
I aimed low the first year. I hit one of the "claw back" thresholds but it seemed to work out. And of course they do not claw back the subsidies to co-pays in a silver plan. So aim low.

This year I reported when selecting my plan higher income. They left my subsidy the same (Virginia). Not sure why.

I have worked "clawback" taxes into my year end tax planning. Not expecting any big surprises.

I always have a basis for my estimate. So if there is an inquiry (unlikely) I can explain why my estimate was low.
 
The APTC repayment limitation is a revelation — surprising. You could even call it a loophole. It’s also good to see you mention how the Silver plan options improve. I thought it was too good to be true, but I’ll look more seriously at those now, though they still may not work for me.
It's not a "loophole". It is an intended consequence based on the law.

But it is certainly a good provision to understand!
 
I believe the repayment limitations would bite it, too, if the ARPA provisions are not extended.

The repayment limitations were in place before ARPA, so I don't think the two are connected. ARPA provisions could expire and I would expect repayment limitations to remain.

The other thing that is currently scheduled to expire is the 400% of FPL subsidy cliff suspension on 1/1/2026. I don't recall if they were part of ARPA or a different law, but I do know it is expiring on the same day as the extended subsidies.
 
There's no big downside to shooting low except the time it might take to put together the documentation they might ask for. If they don't like the proof, they can take away the APTC. But as you were informed, it all washes out to the same total in the end. Or it could be a lower total, as there's that repayment loophole. I never got there, and I can't see that "working" very often, but have no data on that. By shooting low, you're just delaying an expense. Some people would rather have "even" expenses, but paying taxes is a lumpy one, so having a little bigger lump might not make any difference.
I assumed the same when I first started ACA. But It does not all wash out in the end if your MAGI remains under 400% of FPL. The amount you have to repay is limited to a max of $3150 for the entire year.
 
The biggest concern if you under report income is being placed into Medicaid. I've been in the ACA for 7 years now, and one year reported my income too low , and was placed into Medicaid. That was a big mistake, because all our doctors didn't take Medicaid that year. I make sure now to stay around the $35-$38K income range.
Yup, always kept my MAGI between 125% and 150% of FPL.
But this misses on something very important that I ran into when attempting to re-enroll last month for 2025 coverage. Despite estimating my income for 2025 to be $30,000 as a single person, which puts me squarely into the ACA area again, one of the questions asked for my November 2024 income. My Nov income was very low, so I entered it. So, when I submitted, it said that I may qualify for Medicaid and to wait to hear back from the state. So I wasn't allowed to re-enroll into my ACA insurance plan for 2025. Well, this seemed ridiculous, but I was able to go back in and update my applications and report a higher income for November 2024, then I was able to re-enroll in my ACA plan for 2025. I never had to change my 2025 estimated income.

Moral of the story - Make sure you don't enter too low of a figure for your income of the month you're enrolling in, in addition to entering the estimated MAGI that's in the ACA coverage range for the full year you're applying for ACA coverage for.

Note: This is using the Federal ACA Marketplace at healthcare.gov
 
I assumed the same when I first started ACA. But It does not all wash out in the end if your MAGI remains under 400% of FPL. The amount you have to repay is limited to a max of $3150 for the entire year.
That's what I sloppily called the repayment loophole, but yeah, it doesn't always work out the same, as indicated by your observation and the observation that shooting too low can trigger Medicaid. But generally, for most people, I imagine, shoot high or lowish and after April, you're in the same spot.
 
My state does a 12 month lock in for Medicaid if you report one month low enough. Seems like a good way to do Roth conversions without any negative impacts on health care costs.
 
That's what I sloppily called the repayment loophole, but yeah, it doesn't always work out the same, as indicated by your observation and the observation that shooting too low can trigger Medicaid. But generally, for most people, I imagine, shoot high or lowish and after April, you're in the same spot.
If you shoot low you get more generous copay and deductible subsidies that are never clawed back (silver plans). And the claw back is limited.

So in those circumstances aiming low puts you in better economic shape.
 
But this misses on something very important that I ran into when attempting to re-enroll last month for 2025 coverage. Despite estimating my income for 2025 to be $30,000 as a single person, which puts me squarely into the ACA area again, one of the questions asked for my November 2024 income. My Nov income was very low, so I entered it. So, when I submitted, it said that I may qualify for Medicaid and to wait to hear back from the state. So I wasn't allowed to re-enroll into my ACA insurance plan for 2025. Well, this seemed ridiculous, but I was able to go back in and update my applications and report a higher income for November 2024, then I was able to re-enroll in my ACA plan for 2025. I never had to change my 2025 estimated income.

Moral of the story - Make sure you don't enter too low of a figure for your income of the month you're enrolling in, in addition to entering the estimated MAGI that's in the ACA coverage range for the full year you're applying for ACA coverage for.

Note: This is using the Federal ACA Marketplace at healthcare.gov
On the ACA marketplace I just provided an annual figure-on time. Not sure why you need monthly. Is there some option to report every month?

Also, my income was far lower than the prior year tax return. I never got any questions about that.
 
On the ACA marketplace I just provided an annual figure-on time. Not sure why you need monthly. Is there some option to report every month?

Also, my income was far lower than the prior year tax return. I never got any questions about that.
There should be a way to put that in since that is how they determine if someone goes to Medicaid.
 
I looked into DW and I getting onto ACA this coming year but because we are living on taxable income from our IRA's, the cost was going to be about the same (looking at similar coverage and Dr. availability) as what we are paying in COBRA. So we will go another 12 months on COBRA before we are forced to go the market to get healthcare.
 
I looked into DW and I getting onto ACA this coming year but because we are living on taxable income from our IRA's, the cost was going to be about the same (looking at similar coverage and Dr. availability) as what we are paying in COBRA. So we will go another 12 months on COBRA before we are forced to go the market to get healthcare.
You can save a ton with the ACA compared to COBRA in most cases, unless your income is so high that subsidies aren't there.
 
There should be a way to put that in since that is how they determine if someone goes to Medicaid.

These kinds of things can vary by state. Many states use the federal exchange, but several states (including mine) have their own exchanges, as well as their own approaches to their management of ACA vs. Medicaid.
 
If you shoot low you get more generous copay and deductible subsidies that are never clawed back (silver plans). And the claw back is limited.

So in those circumstances aiming low puts you in better economic shape.
There are people that found silver plans a better deal. Those never made sense for me because I didn't have enough visits for the silver perks to make up for the significant (in my region) difference in bronze to silver premiums. FWIW, back in the day, I always aimed just a hair over what would have put me in Medicaid (something like 203% FPL in my state/situation), then paid the difference come tax time. In all my years of doing that, I never engaged the repayment limitation.

This year, with only two months on ACA, I elected to get zero advanced PTC; I knew with a big "tIRA" withdrawal that I was planning, I was going to get shut-out. And I did. So paid "full price" for my last two months on the ACA. But over the 10 years we were on ACA policies, although I suffered from an "access" perspective (limited network), I was able to enjoy very reasonably priced insurance against big medical bills. Big bills that I never had, but one never knows.
 
On the ACA marketplace I just provided an annual figure-on time. Not sure why you need monthly. Is there some option to report every month?

Also, my income was far lower than the prior year tax return. I never got any questions about that.
It doesn't actually ask for "monthly" income, but rather for the specific month that I'm applying in. Last year, it asked for my December income because I applied in December. This year it asked me for my November income because I applied in November. It asks for the estimated income for the coverage year after the month's income info. You will notice is says "this month's household income" in the eligibility forms below. As noted earlier, this is the federal exchange, and I'm in Illinois.

Here is the original eligibility form they gave me this year before redoing:

1733596417575.png


Below are a couple screenshots from last year's eligibility form, when I hadn't run into the issue because I used my December income that was asked for, which was much higher:

1733596659727.png


1733596500594.png
 
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NY says estimate annual, then divides it by 12 and asks is this your monthly income? If you say no, you put the actual income. Then is says you can use monthly or annual and it lets you choose. Monthly would put you in Medicaid if you say under $1,732.
 
Ok I see that. I think the difference is my "monthly" estimate would have been 1/12 of annual. Stated differently, I did not have a reason to expect materially different income in any month.

If I did then I guess that could have come into play.

Genxguy, thank you for taking the time and effort to explain-and correct-my understanding!
 
We're about to enter our second year in a row as well. We were on it briefly back in 2014 and ended up paying back all of our tax credits at tax time because I went back to work in the middle of that year.

I guessed our MAGI too high for 2024. Way too high. But I also didn't know what I was doing when I did that as I had retired but I hadn't yet started withdrawing from my investments. I'm in a no-income tax state, so it's only the federal side I need to deal with. To rectify it for this year, I'm going to do a Roth conversion up to the MAGI I originally estimated and move on.

For 2025, I did a much better job. Not that it's going to matter much. We'll have tax credits for Jan-Mar, then in April my wife will go on medicare. At that point, our tax credits will pretty much disappear until the middle of 2026 when I, too, go on medicare. If I end up doing additional Roth conversions at the end of 2025, I'll likely end up having to pay back the tax credits.

Cheers.
 
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