About 620,000 ACA marketplace enrollees with income in the 100-150% FPL range have enrolled in bronze plans. Having just implemented continuous year-round enrollment for people with income up to 150% FPL, CMS is openly -- in fact expressly -- inviting these bronze plan enrollees to switch to silver. I have a post at healthinsurance.org amplifying this invitation:
At incomes up to 250% FPL, Silver plans are enhanced by cost-sharing reduction, which reduces out-of-pocket costs. CSR is particularly strong at incomes up to 150% FPL, where it reduces the average deductible to $146 and the average annual out-of-pocket maximum – the most an enrollee will pay for in-network care – to $1,208. Bronze plans – in prior years usually the only free option – have deductibles averaging $7,051 and OOP maxes usually in the $7,000-8,700 range.
The post further notes that CMS rulemaking is explicitly tailored to steer low-income enrollees into silver plans, quoting the finalization of the rule establishing the year-round enrollment at income up to 150% FPL:
… enrollees with a newly-enrolling dependent or other household member may not use the new monthly special enrollment period to change to a plan of a different metal level other than a silver-level QHP to enroll together with their newly-enrolling household member, but can stay in the same plan or change to a silver plan to enroll together with the newly-enrolling household member.
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A footnote on the estimate of the number of enrollees with income under 150% FPL: The CMS Public Use Files provide counts of bronze, silver and gold enrollees in each income bracket in all of the 33 states using HealthCare.gov combined, but does not total up these breakouts for all states including those with their own marketplaces. That's basically because breakouts of metal level selection by income are not available for Nevada. To get a total count in the below 100% FPL and 100-150% FPL categories, I created estimates for Nevada, which had 101,411 enrollees as of the end of Open Enrollment. CMS does provide breakouts for Nevada by income level and metal level, without cross-referencing them, and errors in my estimate are unlikely to skew the national totals by more than a percentage point. Based on slightly below average silver selection for Nevada, I estimated that 80% of enrollees in the 100-150% FPL bracket chose silver, 19% bronze, and 1% gold. My national estimate, then: 619,000 bronze enrollees in the 100-150% FPL bracket, and another 48,000 at incomes below 100% FPL -- the normal threshold for subsidy eligibility.
Most enrollees with income below 100% FPL are likely legally present noncitizens subject to the federal five-year bar for Medicaid eligibility, or longer state bars. Noncitizens in this situation are subsidy-eligible at income below 100% FPL. In HealthCare.gov states, 58% of enrollees with income below 100% FPL chose silver plans. That, plus evidence from Covered California's enrollment reports, leads me to believe that perhaps two thirds to three quarters of enrollees below 100% FPL are subsidized. A disproportionate percentage of bronze enrollees below the 100% FPL threshold may be unsubsidized. At 100-150% FPL, probably 98-99% of bronze enrollees are subsidized, but including the sub-100% FPL group would likely bring that down a few percentage points.
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