[Update 12/12/13: Link rot has apparently set in on the paper application. The other noteworthy change is that I’ve been getting reports that the administration had ditched asking for 2012 MAGI at all! That’s just wrong—the regs were written to base the advanced premium credit on 2012 modified adjusted gross income. If you have both 2012 and an estimate of 2014 handy, you should be able to figure out the possibility of clawback. It’s seems stupid that they would actually deny the advance credit based off someone’s guess about income in a year that hasn’t even happened yet.]
If you haven’t heard the news, the Administration put out draft forms of what the health exchange applications will be, for Affordable Care Act coverage.
You can find the blog post and the link to the relevant draft application (long form – single or family), here.
If you’ve been following my posts on this, what was noteworthy is that the income information the proposed applications look for is different than what is in the regulations. The regulations seek the most current “adjusted gross income”, which for practically everybody will be 2012’s this October. The draft application asks what are you currently making, and what do you plan to make in 2014?
This is a nice end run around the problem I’ve called the Obamacare Clawback. If your 2014 income is substantially higher than what you had for AGI in 2012, you would be required to pay back some (or all!) of the government’s health care credit. (Quick review: your cost of insurance on the Exchange is a net of what is left AFTER you are advanced a federal credit. That credit is tentatively based on 2012 AGI, or now, apparently, your guess about 2013 or 2014 income.)
I’m glad the Administration did it this way. The draft applications are short and sweet. If any individual would have a problem concerning escalating income (not a bad problem to have), better to get it out in the open at the start.
Myself, I plan to use 2012 AGI, like the original regs say. If there is a clawback, I will deal with it in April 2015.