Affordable Care Act: Will Your Group Health Plan be Affordable in 2021?

The Affordable Care Act’s affordability threshold for employer-sponsored group health plans will increase to 9.83 percent in 2021. The affordability threshold is currently 9.78 percent. The impending increase primarily affects employers with 50 or more full-time or full-time equivalent employees. The ACA generally requires these Applicable Large Employers (ALEs) to offer full-time employees “affordable” minimum essential health care coverage; otherwise, they may have to pay the ACA’s employer shared responsibility (pay-or-play) penalty.

Affordability is calculated as a percentage of household income. In 2021, the amount an employee must pay (required contribution) for the lowest-cost, self-only coverage option offered by their ALE cannot be more than 9.83 percent of the employee's household income. If it is, the employee’s offer of health coverage is not considered affordable and the ALE may be assessed a penalty under the ACA.

ALEs can use one of the ACA’s affordability safe harbors to determine the most employees can be required to pay without exceeding the affordability threshold. For example, if Sam earned $12 per hour in 2021 and worked 40 hours per week for 52 weeks, Sam’s monthly required contribution for coverage under the ALE’s 2021 calendar year group health plan cannot exceed:

• $204.46 per month, if using the W-2 Safe Harbor Method;
• $153.35 per month, if using the Rate of Pay Safe Harbor Method; or
• $104.53 per month, if using the Federal Poverty Line Safe Harbor Method.

Even though the affordability threshold for group health plans beginning in 2021 is only .05 percent higher than the year before, the difference can be consequential. To ensure compliance with the ACA’s affordability requirement in 2021, ALEs need to evaluate and possibly adjust their health plan pricing options, cost-sharing structure, and in some cases, compensation levels.

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