FoIB Allison Bell has an excellent overview of proposed new IRS rules regarding employees who may qualify for subsidies. There's a lot of good stuff here, but I want to focus on two items that we'll call problematic:
First, regular readers know that subsidy calculations are, at best, a crapshoot. That is, very few (if any) people know what their next year's income is going to be with total accuracy. As we've noted time and again, Ouija boards lack dollar signs. So the Rocket Surgeons in DC© have decided to "to get tough about clawing back premium tax credits provided for taxpayers who appear to have "recklessly or intentionally" provided inaccurate information about how high their future income might be."
Heck of a lot of room for creative interpretation on their part, no? Perhaps if one just claimed there was no intention to overestimate?
And second, there's actually an appeals process for folks who believe they've been wrongly denied a subsidy, but it's apparently quite time consuming and as a result, "resolving eligibility appeals has been taking so long that key premium payment deadlines have passed."
So what's their solution?
This is pure genius: "Officials say they want to clear up those conflicts by giving a taxpayer who wins an eligibility appeal up to 120 days after the decision has been made to pay the taxpayer's share of the premium bill."
Are they not aware that the maximum grace period for folks buying subsidized coverage is only 90 days? How are they going to enforce this? It's almost as if they have no idea what they're doing.
First, regular readers know that subsidy calculations are, at best, a crapshoot. That is, very few (if any) people know what their next year's income is going to be with total accuracy. As we've noted time and again, Ouija boards lack dollar signs. So the Rocket Surgeons in DC© have decided to "to get tough about clawing back premium tax credits provided for taxpayers who appear to have "recklessly or intentionally" provided inaccurate information about how high their future income might be."
Heck of a lot of room for creative interpretation on their part, no? Perhaps if one just claimed there was no intention to overestimate?
And second, there's actually an appeals process for folks who believe they've been wrongly denied a subsidy, but it's apparently quite time consuming and as a result, "resolving eligibility appeals has been taking so long that key premium payment deadlines have passed."
So what's their solution?
This is pure genius: "Officials say they want to clear up those conflicts by giving a taxpayer who wins an eligibility appeal up to 120 days after the decision has been made to pay the taxpayer's share of the premium bill."
Are they not aware that the maximum grace period for folks buying subsidized coverage is only 90 days? How are they going to enforce this? It's almost as if they have no idea what they're doing.
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