How not to explain ACA metal levels (and, I hope, how to)

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I have a post up at healthinsurance.org that aims to guide ACA marketplace shoppers in selecting the metal level (bronze, silver, gold, very occasionally platform) that works best for them. My opener was the product of a lot of trial and error:

When shopping for a health plan in the ACA marketplace, it’s important to recognize that while Bronze, Gold and Platinum plans have the same value no matter who is shopping, the value of Silver plans varies with income. Accordingly, the metal level that will best suit your needs is also likely to vary with income.

That basic fact is a given to anyone who's studied the marketplace and so may seem obvious. But it's counterintuitive, and it's the single most salient fact about metal level selection.  HealthCare.gov's guide to the metal levels all but completely obscures it (and many other guides follow suit):

Plans in the Marketplace are presented in 4 “metal” categories: Bronze, Silver, Gold, and Platinum. (“Catastrophic” plans are also available to some people.)

FYIMetal categories are based on how you and your plan split the costs of your health care. They have nothing to do with quality of care.

How you and your insurance plan split costs

Estimated averages for a typical population. Your costs will vary.

Plan Category	The insurance company pays	You pay
Bronze	60%	40%
Silver	70%	30%
Gold	80%	20%
Platinum	90%	10%

In the 33 states using the federal exchange, Healthcare.gov, in 2022, 93% of silver plan enrollees obtained one of three levels of Cost Sharing Reduction. For 83% of silver enrollees, CSR raised the value of a silver plan to either 94% (above platinum) or 87% (above gold)*. The next page segment does mention CSR. But not before the reader has absorbed this near-misinformation. And not in a way that gives any real idea of the degree to which CSR (at incomes up to 200% FPL) transforms the value of a silver plan:

Silver

• Moderate monthly premium
• Moderate costs when you need care
• Silver deductibles — the costs you pay yourself before your plan pays anything — are usually lower than those of Bronze plans.

IMPORTANT:If you qualify for cost-sharing reductions you must pick a Silver plan to get the extra savings. You can save hundreds or even thousands of dollars per year if you use a lot of care.

• Good choice if: You qualify for “extra savings” — or, if not, if you’re willing to pay a slightly higher monthly premium than Bronze to have more of your routine care covered.

Compounding the confusion, the overview of platinum plans that follows lower down on the page asserts that platinum has the "lowest costs when you get care." That's not true for the 60% of silver plan enrollees in HealthCare.gov states who obtained silver with 94% AV.

In fairness, HealthCare.gov's "shop for plans" feature and application do a better but by no means perfect job signposting the importance of CSR. In 2022, 14% of those who qualified for free silver plans boosted by CSR to 94% AV chose bronze or other metal levels.

My main organizing point in the healthinsurance.org piece is that silver is almost always the best choice at incomes up to 200% FPL, the threshold for strong CSR, whereas bronze or gold plans are usually better choices for those with incomes above the 200% FPL. The preference for bronze/gold at higher incomes is due in part to silver loading -- the pricing of CSR directly into silver plan premiums, which began in 2018 after Trump cut off direct reimbursement to insurers of the value of CSR in October 2017. Since CSR raises average silver AVs well over 80%, 

Generally, if you buy a Silver plan and you have an income where CSR is weak or not available, you’re paying for CSR that you don’t get.

The ACA  marketplace subsidy structure and choice architecture are convoluted and confusing. It's awfully hard to straighten the skein verbally in one go. If you're interested in such matters, please take a look.

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* The CMS public use files do not include the same detailed breakouts for all states, including the 18 states (including DC) that run their own exchanges, that they provide for HealthCare.gov states. Including the SBE states would reduce the overall percentage of silver enrollees who obtain CSR modestly, and the percentage obtaining 94% AV CSR somewhat more sharply. That's because all the states that run their own exchanges have enacted the ACA Medicaid expansion, and so eligibility for marketplace subsidies in those states begins at 138% FPL, as opposed to the 100% FPL threshold in the 12 nonexpansion states, all of which use HealthCare.gov. Those states account for a bit more than half of all marketplace enrollment, and half of the enrollment in those states is at incomes below 150% FPL (the threshold for 94% AV CSR).

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