Rev Proc 2018-43, 2018-36 IRB
In a Revenue Procedure, IRS has provided the 2018 monthly national average premium for qualified health plans that have a bronze level of coverage. This figure is used in determining the maximum individual shared responsibility payment under Code Sec. 5000A(c)(1)(B) for 2018—the last year it’s in effect.
Observation: For months beginning after Dec. 31, 2018, the Tax Cuts and Jobs Act (TCJA; P.L. 115-97, 12/22/2017) eliminated the individual shared responsibility payment under Code Sec. 5000A (i.e., reduced it to zero).
Background. Beginning in 2014 and continuing through 2018, under Code Sec. 5000A, if a taxpayer or an individual for whom the taxpayer is liable isn’t covered under minimum essential coverage for one or more months, then, unless an exemption applies, the taxpayer is liable for the individual shared responsibility payment on his or her return. Married individuals who file a joint return for a tax year are jointly liable. The amount of a taxpayer’s shared responsibility payment is based, in part, on the number of individuals a taxpayer is responsible for who do not have minimum essential coverage. (Code Sec. 5000A(c)(3)(B), Reg. § 1.5000A-4)
For each tax year during which its in effect, the individual shared responsibility payment is the lesser of: (1) the sum of the monthly penalty amounts; or (2) the sum of the monthly national average bronze plan premiums for the “shared responsibility family.” (Reg. § 1.5000A-4(a)) Shared responsibility family means, for a month in a tax year, all nonexempt individuals for whom the taxpayer and the taxpayer’s spouse (if the taxpayer is married and files a joint return with the spouse) are liable for the shared responsibility payment under Code Sec. 5000A for that tax year. (Reg. § 1.5000A-1(d)(17)) The monthly national average bronze plan premium means, for a month for which a shared responsibility payment is imposed, 1/12 of the annual national average premium for qualified health plans that (a) have a bronze level of coverage, (b) would provide coverage for the taxpayer’s shared responsibility family members, and (c) are offered through Exchanges for plan years beginning in a calendar year with or within which the tax year ends. (Code Sec. 5000A(c)(1)(B), Reg. § 1.5000A-4(c))
Rev Proc 2014-46, 2014-33 IRB 367, Sec. 2, provides an explanation of the methodology used to determine the monthly national average premium amount.
Monthly national average bronze plan premium for 2018. Rev Proc 2018-43 provides, for purposes of Code Sec. 5000A(c)(1)(B) and Reg. § 1.5000A-4, that the monthly national average premium for qualified health plans that have a bronze level of coverage and are offered through Exchanges in 2018 is $283 (up from $272 for 2017) per individual and $1,415 (up from $1,360 for 2017) for a shared responsibility family with five or more members.
References: For the amount of penalty for failure to maintain health insurance coverage, see FTC 2d/FIN ¶ V-3900 ; United States Tax Reporter ¶ 50,00A4.2.
