IRS Issues Guidance on Overlapping Coverage

At last, we have IRS guidance informing consumers and tax preparers about issues with overlapping coverage through Medicaid and the Marketplace. I described this problem in a recent blog, highlighting the confusion that could result from 1095 forms showing dual coverage in Medicaid and the Marketplace. We have been concerned that during the tax reconciliation process, consumers and tax preparers might draw the conclusion that they should not have received premium tax credits for the overlapping months and could end up paying back the tax credits. We have been talking with federal officials about this issue for many months, so today’s guidance is indeed welcome.

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