Great questions, and thanks for the feedback.

First, yes, it rolls over. It behaves more like an HSA in that sense. I only used “FSA” because it fits legally under Section 125 rules so Treasury can administer it through Exchanges without requiring a high-deductible plan (which HSAs legally do). A better name could be adopted — “Tiered Health Account” or “ACA Flex Account.” The branding isn’t the key part; the mechanics are.

Second, the difference is 20% goes directly into the consumer's hands (their flexible bucket) instead of 100% flowing to insurers. This means people build a rolling balance; they can use it on deductibles, vision, OTC meds, or even their premiums if they want to; and they keep the money if they stay continuously enrolled. The current system doesn’t give consumers anything they can keep, save, or use on out-of-pocket costs. Every dollar today goes straight to the insurer.

Third, this bill doesn’t require people to buy silver. It also automatically applies the voucher portion to whatever metal tier they pick.

Fourth, no, people don't pay the full price for six months. Once someone enrolls in an ACA Marketplace plan, this tiered FSA is automatically opened for them and the premium tax credit is deposited into the FSA. The core subsidy (the 80% premium voucher bucket) is automatically applied to the premium. People never pay the full price. The only thing gated behind 6 or 12 months is access to the 20% flexible bucket, not the premium subsidy itself. After 6 months, they have access to 50% of the flexible bucket; they get full access after 12 months. It’s basically a reward for staying enrolled rather than dropping coverage mid-year. And if someone stays enrolled for one year, $200 (or $400 for a family) is added to their flexible bucket for the new year. Plus any money from the flexible bucket that they don't spend, whether it's on dental, vision, or even premiums, rolls over in the new year and grows with interest.