CMS has recently issued guidance to DHCS about how to help those enrolled in Covered California plans with APTCs who are later determined eligible for Medi-Cal. DHCS has issued this letter to explain that those who transition from APTCs to Medi-Cal may have retroactive Medi-Cal coverage that can be used for unpaid medical expenses received up to three months prior to the month of transition, where the QHP will be the primary payor and Medi-Cal the secondary payor.
Those enrolled in QHPs with APTCs who later become eligible for Medi-Cal are not disqualified from receiving tax credits until the month following the Medi-Cal approval, even if Medi-Cal eligibility is retroactive. Changes to enrollment are to be made prospectively and there would be no retroactive termination of enrollment from a QHP or termination from APTC.
Individuals do not lose eligibility for APTC until the first day of the month following the approval. An individual can claim the tax credits for these months, if otherwise eligible. Meanwhile, there is no requirement to be refunded premiums paid of QHP coverage.
DHCS ACWDL 16-08 (4/21/16).