Complications arising from the Affordable Care Act (ACA) premium tax credits (PTCs) are causing millions of people to effectively break the law. People who benefit from advance premium tax credits (APTCs) must file tax returns and include a form to reconcile the advanced amount to the actual end-of-year entitled amount. The failure of so many people to fulfill this new legal requirement has led the government to spend more than it should have as APTCs tend to be higher than legally entitled amounts.

The big news is that tax filers, as of April 28, 2016, reported $15.8 billion in total APTC payments. According to data released by HHS, I estimate the amount of APTCs paid in 2015 equaled $26.7 billion—nearly $11 billion more than the amount reported by tax filers. It appears that about 3 million households that received an APTC in 2015 had not filed the required paperwork with the Internal Revenue Service (IRS) by the end of April 2016.

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