IRS Addresses Eligibility for Premium Tax Credit While Also Enrolled in Medicaid or CHIP

The IRS recently posted an FAQ that clarifies eligibility for the Premium Tax Credit, under the Affordable Care Act, for individuals who may have also been inadvertently enrolled in both Medicaid coverage. Here is how the situation may arise:

I enrolled in a qualified health plan with Advanced Premium Tax Credit (APTC) based on a Marketplace determination or assessment that I was ineligible for Medicaid or CHIP coverage. Subsequently, I was determined eligible for Medicaid and was enrolled for several months while I was enrolled in the qualified health plan.

Am I treated as eligible for Medicaid, and therefore, ineligible for the premium tax credit for these months?

Generally, no. If a Marketplace makes a determination or assessment that an individual is ineligible for Medicaid or CHIP, and eligible for APTC when the individual enrolls in a qualified health plan, the individual is treated as not eligible for Medicaid or CHIP, for purposes of the premium tax credit, for the duration of the period of coverage under the qualified health plan (generally, the rest of the plan year). The Marketplace may periodically check state Medicaid data to identify consumers who may be dual-enrolled, and direct them to return to the Marketplace to discontinue their APTC. If you believe that you may currently be enrolled in both Medicaid and a qualified health plan with advance credit payments, you should contact the Marketplace immediately.

More Information: Resolving Information Form 1095 Conflicts (March 4, 2016).