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Health Coverage Tax Credit - Click here to go to the IRS site.

Sample 13441-A Forms for various situations can be found at the following link:

Refer to the Questions and Answers ( on the IRS website for further guidance on the types of health insurance coverage that qualify for the HCTC in 2019.

ANSWER:  No, the IRS has agreed to update your premium amounts through a spreadsheet provided by BCBSM for all current enrollees, even if you are changing plans (e.g. moving from Bronze to Gold).  However, if you are changing plans, make sure you send the DSRA-BT/BCBSM enrollment form to BCBSM by November 13th.

ANSWER: The very first thing you should do is to complete and mail to the IRS the 13441-A form as a new registrant. A sample form is available at the following link to help guide you AMP link.  Include a copy of a BCBSM invoice issued in the past 60 days and handwrite in the 2018 premium on this invoice (i.e. 2019 premium = $_____).  The invoice should include the Health Plan ID# which for all DSRA BT plans is 38-2069753 and the Group ID# which for all DSRA BT plans is 007023339. Record these ID#’s on the invoice if they are not present. The IRS needs to see that you currently have coverage through the DSRA BT. You will find the HCTC AMP plan premiums on page 4 of the DSRA-BT/BCBSM enrollment form.  BCBSM will not set you up in a HCTC AMP plan until you provide them with a copy of the IRS issued “You are Enrolled Letter”. As soon as you receive the “Enrolled Letter” from the IRS, send a copy of that and your BCBSM enrollment form to BCBSM. Make sure you check the box for “HCTC AMP Enrollment or Change” in Section 1 and the “HCTC AMP” medical plan that you submitted to the IRS in Section 8. You will have to continue paying the full premium until you receive your IRS Enrolled Letter. We recommend that you call BCBSM and confirm the change to your coverage after allowing BCBSM a week to receive and process your request.

ANSWER: The very first thing you need to do is complete the BCBSM enrollment form for the Non-HCTC version of the bundled plan offered by the DSRA Benefit Trust. Check the “New Enrollment” box in Section 1.  To save time, email or fax the form to BCBSM. Wait a few days and then call BCBSM and ask for a letter from BCBSM that indicates you are enrolled with them for January 2019. Your BCBSM invoice will not be received until approx. December 10, which is why you need to request the letter. Ask BCBSM to include the Health Plan ID# and Group Plan ID# and the monthly premium. This is a required first step because the IRS requires proof you are enrolled with the DSRA-BT plan through BCBSM.

Upon your receipt of the BCBSM letter, immediately complete the 13441-A form and submit along with a copy of the BCBSM letter. If BCBSM did not include the plan ID#’s or 2018 premium in the letter, you should record them on the face of the letter. When you receive your “Enrolled Letter” from the IRS, send a new BCBSM enrollment form along with the “Enrolled Letter” to BCBSM. Make sure you check the “HCTC AMP Enrollment or Change” box in Section 1.  Again, use email or fax to save time. Use this enrollment to advise BCBSM that you want to be transferred to the HCTC AMP eligible plan. You must complete this process for the payment to be successfully received from the IRS and credited to your account by BCBSM. Once BCBSM updates your account to the AMP plan, you will no longer receive an invoice from BCBSM. Until this process is completed you must pay 100% of the premium to BCBSM. If it gets too late into the month of November before you submit your first enrollment form to BCBSM, you will probably have to pay the full months premium for January to BCBSM and then recover the overpayment when you file your 2018 tax return or you can use IRS Form 14095.  Note that it could take up to 12 weeks to process your refund if you use Form 14095.


ANSWER: The Trust Agreement approved during the Delphi bankruptcy clearly stipulates that the limited funds paid to the Trust by Delphi were specifically for the benefit of those retired and receiving their pension as of April 1, 2009. Please see the Trust agreement posted at the DSRA BT website.

ANSWER: NO, the guidelines for who is eligible for a DSRA BT subsidy have not been changed for 2019. See the 2019 Subsidy section of the Guide for more details.


ANSWER: Your spouse is eligible for the HCTC until you reach age 67 if they are under 65.  At age 67, when HCTC eligibility ends, the pre-65 spouse will be eligible for a DSRA-BT QFM subsidy for 24 months (if you are a salaried retiree and retired on or before April 1, 2009) until the retiree reaches the age of 69 or the spouse reaches age 65, whichever comes first. The DSRA-BT does not offer a subsidy for the QFM once the retiree reaches age 69.  To receive this DSRA-BT subsidy, a new enrollment form must be submitted to BCBSM requesting the subsidy.  This is required, even from current enrollees

ANSWER: No, you must have started drawing your PBGC pension prior to April 2, 2009 to be eligible for a subsidy.

ANSWER: The reauthorized HCTC is set to expire 12-31-2019 and is retroactive back to1-1-2014.

ANSWER: Yes, they are eligible if you also have medical coverage from BCBSM.  In fact, if you are in the HCTC AMP you are required to have dental & vision. If you have stand-alone dental and vision, the HCTC does not cover their premium cost.

ANSWER: YES. Retirement (involuntary loss of other insurance coverage) is a "Qualifying Event" and as a result makes you eligible to change your medical coverage without waiting for the annual open enrollment window.


ANSWER: NO, you can purchase a Non-HCTC plan from the Trust and recoup the HCTC on your tax return through IRS form 8885. Or you can buy an HCTC eligible plan from another carrier and recoup the HCTC on your tax return. If you plan to use the tax return method to recoup the HCTC, you do not have to buy a bundled plan. In this situation, you have the flexibility to decide if you want to bundle dental and or vision coverage.

ANSWER: You qualify for the HCTC if you receive your pension from the PBGC, you are 55-64 years of age and you are not receiving coverage through Medicare. There are other ways to meet the eligibility requirements for the HCTC. They can be found at the IRS website. We suggest that you bookmark the following link from the IRS and review periodically for any new updates:

ANSWER:We have been advised by our IRS/HCTC liaison that all pre-65 medical plans offered by the VEBA in Non-Medicare situations are HCTC eligible.


ANSWER: The HCTC does not apply to individuals that are 65 or older, or on Medicare.

ANSWER: We clearly want to maintain HCTC eligibility when we win the pension battle.  All of our current scenarios take this into account according to our legal team.  Maintaining the HCTC is a priority.

ANSWER: Yes, loss of the HCTC is considered a qualifying life event (QLE).  As such, you are eligible to downgrade your plan (i.e. from Gold to Copper) if you wish.  We also asked the IRS if the government would consider it a QLE so a person could enroll in an ACA plan in the Marketplace mid-year.  Their response was that it would make sense that the loss of the majority of funding would be a qualifying event. That said, the IRS would not give us an answer, and instead indicated that the member would need to contact the Marketplace in the state where they are purchasing a policy and get an individual determination.


ANSWER: If your retired spouse had the surviving spouse (SS) option as a part of his/her pension, once you initiate the SS option and become the pensioner of record with the PBGC and start receiving benefits, you are now eligible for the HCTC for as long as the HCTC is in effect. You must purchase qualified medical insurance and be age 55-64. In this situation, the QFM guidelines and limitations do not apply.

Answer: An acquired spouse may be added to your coverage upon marriage. A former spouse is eligible if he or she provides a statement from the PBGC confirming that he/she has become a pension recipient in his or her own right due to the divorce (under a QDRO). A former spouse is not eligible for coverage in
the medical, dental or vision plans unless eligible for PBGC pension, except for a former spouse who is a QFM within 24 months of divorce. A former spouse is NOT eligible for voluntary term life insurance.

ANSWER: Yes you qualify for the HCTC. You are considered a PBGC pensioner, just like your ex-spouse, so long as the HCTC is in effect, you can take advantage of this benefit. The qualified family member limitations do not apply any longer. Just remember, you must purchase a qualified medical insurance plan and be age 55-64. PBGC uploads eligibility records monthly, but depending on when you are identified as a pensioner, your Social Security Number (SSN) may come up as ineligible. To help avoid any issues, we strongly encourage attaching a letter of eligibility (from PBGC) or a 1099-R (showing pension distribution) so if your SSN does show up as ineligible, it can be overrode.

ANSWER: YES, if you pay more than 50% of the cost of your COBRA insurance, you qualify for the HCTC.  However, these plans are not eligible for the HCTC AMP program.  You will have to use your tax return to recoup the 72.5% of premiums paid.

ANSWER: Yes, expiration of COBRA coverage would be considered a “Qualifying Life Event”.

ANSWER:  No, the retiree must be a participant in one of our plans for the dependent spouse to qualify for our insurance.

ANSWER: YES, you must be drawing your PBGC pension to qualify.

ANSWER: No, the HCTC will be available effective the month you start drawing your pension from the PBGC.

ANSWER: Current interpretation is that once you no longer receive a PBGC pension, you are no longer eligible for the HCTC.  However, these people will be eligible for a DSRA-BT subsidy if they satisfy the following conditions:

  1. Delphi Salaried retiree
  2. Retirement date previous to 4-2-2009
  3. Be the Age of 55 to 64
  4. Provide proof of lump sum distribution or agreement between both parties to a defined time period of pension payments.
ANSWER:  Your spouse qualifies for the HCTC until you have been on Medicare for 24 months.  At that point, they qualify for a DSRA-BT Special Circumstance subsidy if you retired on or before April 1, 2009 and they are still under 65.

Health Savings Account


The recommendation is to establish H S A accounts individually. The reason being is with 2 individual accounts, each  spouse can take advantage of any age based or employer based benefits specific to that individual. Individual H S A’s can be established jointly for a married couple or family if you choose to do so for ease of managing the maximum amount contributed and possibly saving account fees. Setting up individual H S A’s will not change the way the IRS determines your H S A contribution limit. The contribution limit is determined by the Internal Revenue Service (IRS) and the IRS views spouses as one tax unit, even if filing as “married filing separately,” so if either spouse is eligible for a family contribution limit, that is intended to cover both spouses.

Yes, as long as the HDHP meets the definition set by the IRS of an HSA-qualified plan. The DSRA-BT BRONZE and COPPER medical plans meet these requirements. 

 No. At this time, Tricare does not offer a qualified HDHP. Therefore, if you are covered by Tricare, you cannot open an HSA

 Maybe. If the plan is a qualified HDHP, you can open an HSA

No. You cannot open an HSA if you are currently enrolled in Medicaid. Medicaid is not a qualified HDHP.

No. If you are enrolled in Medicare, you may not open an HSA. If you previously opened an HSA, you are able to spend that money, but cannot add additional money. 

YesThe same types of investments permitted for IRAs are allowed for HSAs, including stocks, bonds, mutual funds, and certificates of deposit. 
Contact your bank or financial institution to see if they offer Health Savings Accounts. 

The level of coverage in the BRONZE or COPPER plans determines your HSA contribution amount. If you have single coverage, you can contribute up to the singe HSA maximum. If you have family coverage (i.e. if you elected Two-Person or Family), you can contribute up to the family maximum, regardless of whether the additional family members are also covered by a non-HDHP. 

YesAs long as you are covered by a HDHP by December 1st of the current plan year and remain covered by a HDHP during the entire following year, you may contribute the full annual amount. 

You may contribute money into your HSA up to the annual IRS allowable maximum. See the 2016 Guide to Benefits for Pre-65 Members for further details. 

When researching HSA financial institutions, there are several things that you will want to consider. For example: 

Is there a set up fee? 
Is there a monthly maintenance fee? 

Distribution Access
- Will I be issued a debit card or checks? 
- Will I be able to access my funds via an ATM? 

Interest Rate
Will my money gain interest over time? 

- Can I invest my money? 
- Is there an account minimum? 
- What investment funds are available? 

Online Access
Will I be able to access my funds online? 

What type of statements will I receive? How often?

As the account holder, you control how the money is invested. You can also choose not to invest your money.
No. It is your responsibility to keep track of the amounts deposited and spent from your account, just like a normal savings or checking account. 

Affordable Care Act


Simply put, a “health insurance exchange” is a marketplace for purchasing health coverage.
However, the term takes on special meaning under the ACA, because the ACA requires that a “Public Exchange” – one that is operated by either the state or federal government - is established in each state effective in January of 2014. Two primary purposes of the Public Exchange under the ACA are: 1) to provide options for the purchase of health insurance coverage so that individuals can meet the new federal requirement to buy health insurance, and 2) to provide low income individuals the opportunity to qualify for and receive financial assistance with health insurance premiums and out-of-pocket medical expenses. (Please refer to FAQ #4 for details regarding household income levels that will trigger assistance with health premiums under ACA guidelines.)

The ACA requires the Public Exchange in each state to be available no later than October 1, 2013 so that individuals have time to enroll in a qualified health insurance plan effective January 1, 2014. A private benefit plan such as the DSRA-BT is not eligible to become a Public Exchange, because the ACA requires these to be operated exclusively by the state or federal government.

Many private brokerage firms and insurance companies are setting up private exchanges in order to offer products and services similar to the Public Exchange. DSRA-BT is investigating whether offering a private exchange option would benefit members of the DSRA-BT. However, it is important to note that federal premium tax credits and cost-sharing subsidies are not available in a private exchange.

Under ACA provisions, individuals will qualify for premium tax credits and cost-sharing
subsidies if their household modified adjusted gross income (“MAGI”) falls between 100% and 400% of the Federal Poverty Line (“FPL”). For purposes of this determination, MAGI includes ordinary adjusted gross income (gross income minus exemptions/deductions), any Social Security income benefits (including untaxed benefits), tax-exempt interest received or accrued during the tax year, and foreign earned income. For a helpful tool in determining whether your personal income situation might qualify for federal financial assistance, please refer to the Kaiser Family Foundation website: To determine your household MAGI for qualification purposes, we recommend that you consult your personal tax advisor.

No. The ACA does not require the purchase of either dental or vision coverage in order to
satisfy the individual mandate. In addition, health plans and health insurance policies are not required to include dental and vision coverage. We anticipate that separate dental and vision policies will continue to be available for optional purchase in the private market, as well as in each state’s Public Exchange, although availability in the Public Exchange cannot be verified until each state’s Public Exchange is fully developed. Regardless of availability elsewhere, the intent is to continue offering dental and vision benefit options in the DSRA-BT.

The ACA includes a requirement that most individuals buy minimum essential health
coverage, both for themselves and for children residing in the taxpayer’s household who are also tax
dependents. This requirement – called the “individual mandate” – goes into effect on January 1, 2014. Most types of major medical insurance coverage will satisfy this requirement, including health coverage purchased through an employer and qualified individual health insurance policies purchased on the Public Exchanges or in the private marketplace as well as Medicare Part A, Medicaid or state high risk pool coverage. Health coverage purchased through the DSRA-BT will satisfy this requirement.

If you do not purchase health coverage to satisfy the individual mandate, you will be subject
to a tax penalty beginning with the 2014 taxable year. The penalty is assessed for each adult (including retiree, spouse and children 18 and older who are tax dependents) and child in the taxpayer’s household. The penalty is reported annually and collected as part of the federal Form 1040 filing. The amount of the penalty increases each year according to this schedule:

  • 2014 Penalty: $95 per adult and $47.50 per child under 18 (capped at $285 per family), or 1% of household adjusted gross income (AGI), whichever is greater
  • 2015 Penalty: $325 per adult and $162.50 per child under 18 (capped at $975 per family) or 2% of household AGI, whichever is greater
  • 2016 Penalty: $695 per adult and $347.50 per child under 18 (capped at $2,085 per family) or 2.5% of household AGI, whichever is greater

Kaiser Family Foundation has published a flowchart that is helpful in understanding the individual
mandate. This chart is found at:

Unfortunately, no. Although some members will be eligible for premium tax credits and cost-
sharing subsidies under ACA provisions, such credits/subsidies are only available if individual health
coverage is purchased in a state-based “Public Exchange” established pursuant to ACA requirements.
Individuals cannot receive ACA premium tax credits and cost-sharing subsidies for health coverage
purchased through an employment-based plan such as the DSRA-BT.

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