FREQUENTLY ASKED QUESTIONS -HCTC Updated 08/30/19
The Board of the DSRA-BT has already received many questions regarding the HCTC. If you don't see an answer to your question, please send an e-mail to Lori Ostrander, Secretary. Her e-mail can be accessed through the DSRA-BT website under "Contact Us".
2019 Open Enrollment
FAQ #1: Will I have to submit a new 13441-A enrollment form for 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.
FAQ #2: If I am enrolled in the DSRA-BT BCBSM medical plans but not the AMP (Advance Monthly Payment Program) for December 2018, and want to enroll in the AMP for the first time effective January 2019, what do I need to do?
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 (use New AMP Enrollees file): https://www.dsrabenefittrust.net/dsrabene/index.php/document-center/Health-Coverage-Tax-Credit-(HCTC)/Sample-Documents/
Include a copy of a BCBSM invoice issued in the past 60 days and handwrite in the 2019 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 2019 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 2019 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.
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
FAQ #2: Are the DSRA BT subsidy guidelines changing for 2019?
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.
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 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.
FAQ#1: When does the HCTC expire?
ANSWER:The reauthorized HCTC is set to expire 12-31-2019 and is retroactive back to1-1-2014.
FAQ#2: Is Dental and Vision insurance eligible for the HCTC?
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.
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.
FAQ#1: Who qualifies for the HCTC?
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#2: Are all four medical plans offered by the DSRA-BT, through BCBSM, eligible for the HCTC?
ANSWER: We have been advised by our IRS/HCTC liaison that all pre-65 medical plans offered by the VEBA in Non-Medicare situations ar HCTC eligible.
FAQ #3: 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.
FAQ#4: Will the HCTC apply to those over 65?
ANSWER: The HCTC does not apply to individuals that are 65 or older, or on Medicare.
FAQ#5: What happens to our eligibility for the HCTC if we win our pension battle?
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.
FAQ#6: 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 puchasing 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.
FAQ #8: What happens to coverage in the event of a change in marital status (spouse)?
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.
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, 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.
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”.
FAQ #12: Can my spouse go on one of your plans and utilize the HCTC while I stay on COBRA?
ANSWER: No, the retiree must be a participant in one of our plans for the dependent spouse to qualify for our insurance.
FAQ #14: If I retire mid-year, is the HCTC retroactive back to the first of the year?
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:
- Delphi Salaried retiree
- Retirement date previous to 4-2-2009
- Be the Age of 55 to 64
- 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.
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 2019.