Obama granted a waiver back in march for "skimpy" (nonconforming) plans:
He could be in one of those states.
Of course I won't say this with 100% certainty but I am pretty sure the White House's "transitional" policy isn't in play; it doesn't make any sense for it to be.
We all know that the majority of the ACA provisions didn't take effect until 1/1/14, meaning that up through 12/31/13 plans existed as they always did (with some exceptions). Well, the 1/1/14 date wasn't a hard date, the actual effective date was 1/1/14 or the next renewal,
whichever was later. What happened then, especially in the group market, was many plans were early renewed on 12/1/13 so they could legally exist until their next renewal (12/1/14) without having to comply with the ACA.
The White House's "transitional" policy, created after the "if you like your insurance you can keep it debacle", was wholly separate from the previous provision. The transitional policy stated that if a plan was issued or renewed
before 10/1/13, then that plan could be renewed again in 2014
and 2015 without complying with the provisions of the ACA. In essence, a plan that wasn't early renewed (as above) could be kept longer than a plan that was early renewed.
CMS would accomplish this transitional policy by refusing to enforce the law, effectively choosing to look the other way. The White House and CMS could not force states and insurers to participate in the transitional policy, mainly because it is de facto illegal.
So, if the OP lives in a state that is participating in the transitional policy then the existence of such wouldn't be causing the cancellation and if OP is not in a transitional state then the absence of such doesn't directly cause the cancellation, that would technically be the renewal causing it.
Re: Your point #2. Redefining group coverage to make associations not qualify strikes me as intensely stupid.
Fern
Setting aside what I may or may not think of the policy personally, it does make some regulatory sense. Department of Labor is now involved more than they have ever been, and they use a different definition of employee than HHS did. Since there was no legislative authority to amend the DOL definition, they had to change the HHS definition.
Now the insurer has to underwrite on groups of employees. The associations do not employ the insureds so they cannot be underwritten at that level. This actually kind of closes a loophole where, previously, a bona fide association could not be formed solely for the purpose of obtaining insurance, but everyone knew that most companies only joined the various Chambers for the large group plans but we looked the other way. This has anecdotally been proven by the fact that the Chambers have been lobbying to overturn the rule on the grounds that nobody will join if it remains in place (confirming that they only ever joined for the insurance in the first place).
Just an FYI, That leaves out the fact that people whose income is below 100% of 130% (can't remember which) do NOT qualify for tax credit, there is a minimum income to get tax credits.
100% (with a 5% allowance), since the law was written with the Medicaid expansion being mandatory, there was no donut hole intended. It was the USSC's ruling that Medicaid expansion was an unfunded mandate and thus optional that opened the tax credit donut hole in states not electing to expand Medicaid eligibility.