Bulletin to Marketplaces on Availability of Retroactive Advance Payments of the PTC and CSRs in 2014 Due to Exceptional Circumst

Due to technical issues in establishing automated eligibility and enrollment functionality, Marketplaces have had difficulty in providing timely eligibility determinations to applicants and enrolling qualified individuals in Qualified Health Plans (QHPs) during the open enrollment period for the 2014 coverage year. Such a circumstance may be considered an exceptional circumstance for individuals who were unable to enroll in a QHP through the Marketplace due to these issues. This bulletin provides guidance on the availability of advance payments of the premium tax credit and cost-sharing reductions on a retroactive basis to an issuer, and clarifies the attendant responsibilities of the QHP issuer in this circumstance.