Cost-sharing reduction on the ACA Marketplace comes in three actuarial value tiers: 94%, 87%, and 73%, each triggered by a different FPL income band. All three apply only to Silver plans. A client who qualifies for the 94% tier and enrolls in any other metal receives no CSR, regardless of income.
Key Takeaways
- Cost-sharing reduction on the Marketplace comes in three actuarial value tiers: 94% for households at 100 to 150 percent FPL, 87% for 150 to 200 percent FPL, and 73% for 200 to 250 percent FPL. Standard Silver carries 70% AV with no CSR.
- The 94% Silver tier has cost-sharing close to a Platinum plan. Deductibles as low as $0 and out-of-pocket maxima in the $2,900 range are common on 94% plans, while a standard Bronze at the same income level often carries a deductible above $6,500.
- The 73% Silver tier is only three actuarial value points above standard Silver. At 200 to 250 percent FPL, APTC does more cost-reduction work than the CSR tier itself.
- CSR is only available on Silver plans. A client eligible for the 94% tier who enrolls in Bronze, Gold, or Platinum forfeits the cost-sharing reduction entirely. APTC follows the client to any metal; CSR does not.
- The CSR variant a client sees in a quoting tool is determined entirely by the income entered at intake. An income entered incorrectly at quote time places the client in the wrong Silver variant from the first screen.
The four Silver plan variants on the Marketplace
Every carrier that offers a Silver plan on the Federal Marketplace is required to file four variants of that plan. The underlying plan is identical across all four: same carrier, same network, same formulary. Cost-sharing is the only variable. The four variants are standard Silver at 70% actuarial value, CSR 73, CSR 87, and CSR 94.
Actuarial value measures the percentage of covered health care costs the plan pays, on average, across the enrolled population. A 70% AV plan pays 70 cents of every covered dollar. A 94% AV plan pays 94 cents. The difference between a $0 deductible and a $7,000 deductible at the same carrier and network is exactly that gap.
| Income range | CSR tier (AV) | Typical deductible | Typical OOP max | vs standard Silver |
|---|---|---|---|---|
| 100% to 150% FPL | 94% | $0 to $300 | $2,500 to $3,050 | Comparable to Platinum coverage at a fraction of the gross premium |
| 150% to 200% FPL | 87% | $100 to $900 | $4,500 to $5,200 | Significantly better cost-sharing than standard Silver |
| 200% to 250% FPL | 73% | $500 to $1,500 | $7,000 to $7,800 | Marginally better than standard Silver (70% AV) |
| 250% FPL and above | 70% (standard Silver, no CSR) | $1,500 to $3,500 | $8,500 to $9,450 | No CSR. Standard plan only. |
Illustrative cost-sharing ranges. Actual deductibles and out-of-pocket maxima vary by carrier, plan design, and plan year. Verify specific plan cost-sharing in the live quote before presenting to a client.
Why the 94% Silver tier is frequently the best plan on the page
For a household at 100 to 150 percent FPL, the 94% Silver variant is often the best available plan across all metals, not just the best Silver. The deductible is often $0 to $300. The out-of-pocket maximum often runs under $3,050. A Bronze plan at the same income level typically carries a deductible of $6,500 to $7,500 and an OOP max approaching the federal annual limit.
The APTC at 100 to 150 percent FPL is also very high. After applying the credit, the net Silver premium may be $0 to $20 per month, while the Bronze net premium may also be $0. Both appear similarly priced in the monthly premium view. The client is choosing between a plan with a $0 deductible and one with a $7,000 deductible for nearly the same monthly outlay. Brokers who do not surface that contrast at quote time leave the client making an uninformed decision.
Whether a client is quoted through Quotit, QuoteTurbo, or another platform, the CSR 94 variant appears only if the income entered at intake places the household in the 100 to 150 percent FPL range. This is why intake income accuracy is step one in CSR quoting, not an administrative detail.
For context on how FPL translates to specific dollar thresholds by household size, see what is the federal poverty level and how it affects the ACA subsidy.
The 73% tier: modest gains, often overstated
At 200 to 250 percent FPL, the CSR tier is 73% actuarial value. Standard Silver is 70%. The gap is three percentage points. In practical cost-sharing terms, the deductible on a 73% plan may be $500 to $1,000 lower than the same carrier's standard Silver. The OOP maximum difference is often smaller still.
The 73% tier is still worth choosing over standard Silver for clients in this income band. But the APTC at 200 to 250 percent FPL does more cost-reduction work than the CSR tier does. A broker who presents the 73% tier as dramatically better than standard Silver is overstating the case. A broker who ignores it entirely and quotes only Bronze is leaving a minor but real improvement on the table.
CSR is forfeited on any non-Silver plan
This is where broker errors generate the most downstream calls. A client eligible for the 87% Silver who is quoted and enrolls in Gold receives no CSR. Gold plans carry 80% actuarial value by definition. That is better than standard Silver at 70% AV, but worse than the 87% CSR Silver the client could have had, and Gold costs more in gross premium.
The same logic applies to Platinum (90% AV) and Bronze. Any client who enrolls in a non-Silver plan loses the CSR benefit entirely. APTC, by contrast, follows the client to any metal tier. The credit reduces the net premium of whatever metal the client selects. CSR reduces the cost-sharing of Silver only. For more on how those two subsidies interact, read APTC vs CSR: what brokers must know.
The Bronze vs Silver trap at low income
To illustrate: a 34-year-old in a mid-sized metro area projecting income at 130 percent FPL may see a Bronze plan at $0 net monthly premium after APTC and a 94% CSR Silver at $14 net monthly premium. The Bronze carries a $7,000 deductible. The Silver carries a $150 deductible.
For $168 per year more, that client gets a plan that pays 94 cents of every covered dollar instead of 60. A single ER visit or two specialist appointments makes the difference visible on the first Explanation of Benefits. Most clients who see the comparison side by side choose the Silver.
Illustrative example. Actual premiums, APTC, and cost-sharing depend on rating area, household size, carrier, and plan year. Verify with a live quote before presenting to a client.
The counterintuitive finding: at the lowest income band, Silver is often the cheaper plan on a total cost-of-coverage basis, not Bronze. The label says "$0 net premium" for Bronze. The deductible says something different.
How CSR variants appear in quoting workflows
The four Silver variants share a base plan name on the Marketplace but carry different HIOS plan ID suffixes in the underlying plan data. The 14-character HIOS ID includes a two-character variant code in positions 13 and 14 that distinguishes standard Silver from CSR 73, CSR 87, and CSR 94.
In a quoting workflow, which Silver variant the client sees depends entirely on the household income entered. Enter an income that places the household above 250 percent FPL and the tool shows only standard Silver. Enter an income at 140 percent FPL and the 94% CSR variant appears. The quoting tool is not making a judgment call. It is applying eligibility rules to the income figure.
This is why income questions at intake carry real consequences beyond APTC calculation. An income entered casually from last year's W-2 rather than the current projected MAGI can place a client in the wrong CSR tier from the first plan view. They may never see the variant they actually qualify for.
FAQ
Common broker questions on CSR tiers and Silver plan variants.
Can a client switch from a Bronze plan to a CSR Silver plan outside of OEP?
Only if a qualifying life event opens a Special Enrollment Period. A client who enrolled in Bronze and later realized they should have chosen CSR Silver cannot make that change because OEP has closed. They need a qualifying event such as a move to a new rating area, a household size change, or a job loss that also eliminates employer coverage. Absent a qualifying event, the Bronze plan remains active until the next OEP.
What happens to CSR if a client's income rises above 250 percent FPL mid-year?
The client remains on the CSR Silver variant they enrolled in for the rest of the plan year. CSR is not recalculated or revoked mid-year based on actual income. If the client reports an updated income projection to the Marketplace above 250 percent FPL, the APTC amount will be recalculated on the new projection, but the plan itself and its cost-sharing structure remain unchanged until the next enrollment period. At tax time, Form 8962 reconciles APTC against actual income. CSR is not reconciled at tax time, as it is applied directly to claims by the insurer throughout the year.
Is there a CSR Silver variant for households below 100 percent FPL?
No. APTC eligibility starts at 100 percent FPL, and CSR follows APTC eligibility. Households below 100 percent FPL in Medicaid expansion states are generally directed to Medicaid. In non-expansion states, adults below 100 percent FPL fall into the coverage gap where neither Medicaid nor Marketplace APTC applies. There is no fourth CSR tier for incomes below 100 percent FPL. Brokers in non-expansion states should be familiar with which clients fall into this gap before building a quote.
Are all four Silver plan variants required to have the same network and formulary?
Yes. The four Silver variants on the FFM share the same carrier, the same provider network, and the same drug formulary. Cost-sharing is the only difference between them. A 94% Silver and the standard Silver from the same carrier in the same rating area cover the same hospitals, the same doctors, and the same medications. The variant affects what the client pays when they use the plan, not which providers they can access. If a carrier exits a rating area, all four Silver variants exit with it.
What does the 94% actuarial value actually mean for a typical client?
Actuarial value measures the percentage of covered health care costs the plan is expected to pay across the enrolled population. A 94% AV plan pays 94 cents of every dollar of covered costs, on average. For an individual client, that average plays out through a very low deductible, very low copays, and an out-of-pocket maximum significantly below the federal limit. In practical terms, a client on a 94% Silver who needs surgery, a specialist series, or ongoing prescriptions will have very low personal cost exposure compared to a Bronze enrollee at the same income level.
