Failure to File and Reconcile Addressed by February 5 Guidance
On Friday, the Centers for Medicare and Medicaid Services (CMS) announced a special enrollment period for those who are not enrolled in 2016 coverage due to failing to file a tax return for 2014 and reconcile their APTC. The special enrollment period is described as an effort to help people enroll who might otherwise miss out during the inaugural year of these requirements.
The CMS guidance will help those who were determined ineligible due to failure to file and reconcile rejoin the marketplace once they "[file] a 2014 tax return, [reconcile] APTC paid on their behalf in 2014, and [return] to the Marketplace to update their application and attest to having filed and reconciled 2014 APTC." Those who are eligible for the special enrollment period have until March 31, 2016 to purchase coverage.