The Affordable Care Act's premium tax credit under IRC §36B ² was substantially enhanced by the American Rescue Plan Act of 2021 and extended by the Inflation Reduction Act of 2022 through tax year 2025. ⁴ Section 70110 of OBBBA, and the absence of a PTC extension in its companion provisions, means those enhancements expired on January 1, 2026. The "subsidy cliff" at 400% of the Federal Poverty Level returned, and the PTC cap moved back to 9.5% of household income for those who do qualify.
For our self-employed and early-retiree clients enrolled in Marketplace coverage, 2026 brought a meaningful affordability shock.
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