Dave Anderson highlights an important weakness in the subsidy structure for the ACA marketplace. As income rises, the enrollee's share of the premium for a benchmark silver plan is subject to sudden and irregular bump-ups, which Anderson compares to jolts in marginal tax rates. Take the case of a couple looking to buy a benchmark silver plan:
From $17,000 to$20,000 this couple pays an extra $2 per month for every thousand dollars more they earn a year. Annually this is about a 2% marginal tax rate on the additional income. And then there is a huge bump from $20,000 to $21,000. The benchmark premium suddenly becomes $256 more expensive. This is a 25% marginal rate...The spikes in out-of-pocket (OOP) costs this couple is exposed to as income rises are even more sudden -- and, I think, potentially damaging to family finances -- than the premium spikes. The main benefit cliff is formed by the sudden fadeaway of Cost Sharing Reduction (CSR) subsidies at 201% FPL, where the actuarial value of a silver plan drops from 87% to 73%. CSR disappears entirely at 251% FPL, and the coverage offered by a benchmark silver plan with no CSR, which has an AV of 70%, is clearly underinsurance for those without significant financial resources.
And then the marginal rate drops again when the family increases their earnings from $21,000 to $22,000. The marginal rate for this slice is now about 11%. The marginal rate for couples earning under 300% FPL is in the mid-teens, and then there is a drop in the marginal rate to just under 10% for 300% to 400% FPL and then a potential massive spike as soon as someone earns over 400% FPL.