On December 22, the Internal Revenue Service (IRS) issued Fact Sheet (FS) 2025-10, guidance on the rules governing Affordable Care Act (ACA) health insurance premium tax credits (PTCs) now that the enhancements to the PTCs enacted in 2020 have expired.

The guidance takes the form of questions and answers and includes background on the “how” and the “why” of the PTCs and their now-expired enhancements. FS 2025-20 updates FS 2024-30, the version explaining enhanced PTCs back in September of 2024.

Per the Fact Sheet, “The revisions and additions are as follows:

• Updates to questions related to the limitations on repayment of excess advance payment of the premium tax credit due to the removal of the limitations for tax years beginning after Dec. 31, 2025.
• Updates throughout for minor style clarifications and topic/question renumbering.
• Deletion of questions Q 32 and Qs 35 - 49 about certain Premium Tax Credit rules that do not apply after tax years 2020 and 2021.”

Prospects: If Congress enacts some kind of reinstatement (likely with modifications) to the enhanced PTCs, this fact sheet will become obsolete. However, because it is uncertain whether Congress will agree on a modified reinstatement of the enhanced PTCs, this fact sheet is useful for the time between now and when the issue is finally resolved.

NAIFA Staff Contact: Jayne Fitzgerald – Director – Government Relations, at jfitzgerald@naifa.org.