CCF Submits Comments to Proposed Rule Fixing the Family Glitch

On June 2, 2022, CCF submitted public comments to the Internal Revenue Service related to a proposed rule which would finally fix the “family glitch.”  As my colleague Tricia Brooks recently explained, the family glitch makes many children and other dependents in families offered unaffordable employer-based family coverage ineligible for premium tax credits to purchase health coverage through the marketplaces.  Some families end up uninsured or face undue financial burdens related to their job-based health plans.

As our comments make clear, the proposed rule adopts the most sound and reasonable legal interpretation of the Affordable Care Act’s statutory language related to premium tax credit eligibility of children and other dependents in families offered employer-based coverage.  Moreover, by fixing the family glitch, the proposed rule would: (1) extend the availability of subsidized marketplace coverage to between two to three million children who are currently ineligible, (2) reduce the number of children who would otherwise be uninsured, and (3) ensure that more low-income children now enrolled in Medicaid who may lose such coverage when the COVID-19 public health emergency expires have access to affordable coverage through the marketplaces, rather than becoming newly uninsured.

Edwin Park is a Research Professor at the Georgetown University McCourt School of Public Policy’s Center for Children and Families.