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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: https://www.dsrabenefittrust.net/dsrabene/index.php/document-center/Health-Coverage-Tax-Credit-(HCTC)/Sample-Documents/
Refer to the Questions and Answers (https://www.irs.gov/individuals/hctc-health-plans-q-and-a) on the IRS website for further guidance on the types of health insurance coverage that qualify for the HCTC in 2020.
ANSWER: Yes, you must complete and submit an updated 13441-A form with the new plan level premium amount if you are changing your plan level. The update form should be sent to the Benistar Retiree Service Center 6-8 weeks prior to the change in coverage level.
FAQ #3: If I am enrolled in the DSRA-BT BCBSM medical plans but not the AMP (Advance Monthly Payment Program) for December 2019, and want to enroll in the AMP for the first time effective January 2020, what do I need to do?
The IRS/HCTC may take up to 8 weeks to process your enrollment forms. As soon as you receive the “Enrolled Letter” from the IRS, call the Benistar Retiree Service Center 1-888-588-6682 and provide them with your Participant Identification Number (PIN). You must continue to pay 100% of the BCBSM premium to Benistar until you have received the “Enrolled Letter”. The 27.5% payment for the BCBSM premiums are due by the 10th of each month to the IRS. Print out IRS form #13973 and mail with your payment. If you miss the HCTC AMP premium payment deadline or if you have already paid the 100% BCBSM premium payment to Benistar for the month, you will begin the HCTC AMP 27.5% payment process the following month.
FAQ #4: If I am not an enrollee in the DSRA-BT medical plans for December 2019, and I want to enroll in a HCTC AMP DSRA-BT medical/dental/vision bundled plan from BCBSM for 2020, what do I need to do?
FAQ#1: Why is the DSRA-BT subsidy limited to those salaried retirees who retired on or before April 1, 2009?
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: Yes, the guidelines for who is eligible for a DSRA BT subsidy were expanded to include HCTC eligible participants for January and February of 2020 to accommodate the delay in reauthorization of the HCTC program. The DSRA BT guidelines from March 2020 through the end of the year then reverted back to the 2019 guidelines. See the 2020 Subsidy section of the Guide for more details.
FAQ #3: I am the retiree from Delphi and I am over 65 but my spouse is under 65. Do they qualify for the HCTC? If they don’t, is a subsidy offered to help offset their premium cost?
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 Benistar requesting the subsidy. This is required, even from current enrollees.
FAQ #4: I retired before April 2, 2009 but have delayed drawing my PBGC pension. Do I qualify for a subsidy since I am not eligible for the HCTC?
ANSWER: No, you must have started drawing your PBGC pension prior to April 2, 2009 to be eligible for a subsidy.
FAQ#3: If I’m still working, can I sign up for health care and the HCTC when I retire and not wait for the next open enrollment window?
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: https://www.irs.gov/Credits-&-Deductions/Individuals/HCTC.
FAQ#03: If I buy my healthcare through the government health insurance marketplace (Obamacare), do I qualify for the HCTC?
ANSWER: No, the plans in Obamacare are not eligible.
ANSWER: The HCTC does not apply to individuals that are 65 or older, or on Medicare.
FAQ#06: If I’m not eligible for the QFM subsidy, can my spouse change their medical plan when they lose the HCTC?
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.
FAQ#07: I am a Surviving Spouse of a retiree whose pension is administered by the PBGC. Am I eligible for the HCTC?
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.
FAQ#09: I am divorced from a Delphi retiree and as part of the divorce decree I am receiving a portion of their PBGC pension. Do I qualify for the HCTC?
ANSWER: Yes, if you meet the eligibility requirements of the HCTC program; being between the ages of 55-64, drawing a pension check from the PBGC and enrolled in a qualified insurance plan, 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. The 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 overridden.
FAQ#10: Is COBRA coverage thru GM or Delphi eligible coverage for the HCTC subsidy? What about from other auto employers that purchased Delphi operations?
ANSWER: YES, if you pay more than 50% of the cost of your COBRA insurance, and meet the eligibility requirements of the HCTC program, you qualify for the HCTC. However, these plans are not eligible for the HCTC AMP program. You must file form 8885 on your tax return the following year to recoup the 72.5% of premiums paid.
FAQ#11: If I have COBRA coverage from any previous employer, can I sign up for a DSRA-BT plan when this expires, even if it's mid-year?
ANSWER: Yes, expiration of COBRA coverage would be considered a “Qualifying Life Event”.
ANSWER: YES, spouses have the ability to enroll in the HCTC program and qualified insurance plan as an individual without the retiree enrolling.
ANSWER: YES, you must be drawing your PBGC pension to qualify.
FAQ#15: We have Delphi Hughes retirees in California that chose to take their Delphi/GM pension over a fixed period of 5 or 10 years. They were also promised health insurance until age 65. Will they continue to be eligible for the HCTC until age 65 once their pension has been paid to them in full by 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:
FAQ#16: I am a Delphi salaried retiree who is Medicare Disabled and under 65. Does my under 65 spouse qualify for the HCTC or a DSRA-BT subsidy?
Health Savings Account
Am I eligible to open a Health Savings Account (HSA) if I am 65 years old and eligible for Medicare, but have decided to wait to sign up. I am currently covered by a HDHP?
Am I eligible to open a Health Savings Account (HSA) if I am already enrolled in an HSA, but my spouse would also like to join it - can we have a joint HSA?
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.
Am I eligible to open a Health Savings Account (HSA) if I am covered by a High Deductible Health Plan (HDHP) and I am not enrolled in Medicare and I do not have any other coverage through my spouse?
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.
Yes. The 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.
I just started a new job and have enrolled in the HDHP plan; however, it is in the middle of the plan year. Can I still contribute the full annual amount to my HSA?
Yes. As 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.
When researching HSA financial institutions, there are several things that you will want to consider. For example:
- Will my money gain interest over time?
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
The term “health insurance exchange” has been in the news a lot lately. What is a health insurance exchange, and how does this term apply to me?
Simply put, a “health insurance exchange” is a marketplace for purchasing health coverage.
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.
These FAQs reference federal financial assistance – premium tax credits and cost-sharing subsidies – that will be available to low income individuals beginning on January 1, 2014. How does the ACA define “low income” individuals, and how will I know if I qualify?
Under ACA provisions, individuals will qualify for premium tax credits and cost-sharing
Under the ACA, am I also required to purchase dental and vision coverage in order to meet the individual mandate?
No. The ACA does not require the purchase of either dental or vision coverage in order to
Under the ACA, am I required to purchase health insurance for myself and/or my family? If so, when will this new rule take effect?
The ACA includes a requirement that most individuals buy minimum essential health
What is the penalty if I do not purchase health insurance as required by the ACA’s individual mandate?
If you do not purchase health coverage to satisfy the individual mandate, you will be subject
Kaiser Family Foundation has published a flowchart that is helpful in understanding the individual
Will tax credits or other subsidies under the ACA replace the expiring HCTC program and provide continued premium assistance for my health plan through DSRA-BT?
Unfortunately, no. Although some members will be eligible for premium tax credits and cost-