Changes taking effect in 2026 have sharply expanded the number of Affordable Care Act Marketplace plans that can be paired with a health savings account, according to a new analysis from the Peterson-KFF Health System Tracker. The change could give some consumers access to tax-advantaged savings, but it also links those benefits to coverage with high out-of-pocket costs.
The 2025 federal budget reconciliation law, known as the One Big Beautiful Bill Act or OBBBA, allows all ACA-compliant individual-market bronze and catastrophic plans sold on and off the ACA Marketplaces to qualify as HSA-compatible plans beginning in plan year 2026. Eligibility no longer depends on a plan’s deductible, out-of-pocket maximum or benefit design.
Before the change, many bronze plans and catastrophic plans did not meet the Internal Revenue Service’s definition of a high-deductible health plan. Some provided benefits before the deductible was met, while others had out-of-pocket maximums that prevented them from qualifying. The new law also expanded the rules involving direct primary care arrangements and telehealth coverage provided before a deductible is reached.
What changed for Marketplace coverage
| Area | Change described by Peterson-KFF |
|---|---|
| Bronze plans | All ACA-compliant individual-market plans can be HSA-eligible beginning in 2026. |
| Catastrophic plans | All ACA-compliant individual-market plans can be HSA-eligible beginning in 2026. |
| Additional coverage | Direct primary care arrangements and pre-deductible telehealth coverage are allowed in HSA-eligible plans. |
An HSA is a tax-advantaged savings account available to people enrolled in certain high-deductible health plans. Account holders can use the funds for qualified medical expenses. Peterson-KFF said the availability of Marketplace plans compatible with an HSA has increased substantially since the relevant OBBBA provisions took effect.
The financial benefit can extend beyond paying medical bills. The analysis said Marketplace enrollees may benefit from the tax advantages of contributing to an HSA. It also said some enrollees with incomes above four times the poverty level could potentially use tax-deductible HSA contributions to become eligible for premium tax credits.
Trade-offs for consumers
The expanded eligibility does not eliminate the cost-sharing risks associated with high-deductible coverage. Peterson-KFF said consumers choosing an HSA-eligible Marketplace plan may need to anticipate future health care expenses and income while weighing medical costs against other short-term household spending. The organization characterized the new environment as offering both benefits and risks.
- Tax treatment: HSA contributions can provide tax advantages for eligible Marketplace enrollees.
- Plan design: HSA eligibility is now available across ACA-compliant bronze and catastrophic plans under the new rule, regardless of several deductible and benefit features.
- Household budgeting: High-deductible coverage can require consumers to plan for potentially significant medical expenses before deciding how much to save or spend.
The changes affect the relationship between health coverage and household savings decisions for Marketplace enrollees. A plan’s HSA eligibility may offer another way to set aside money for qualified medical expenses, while the underlying high-deductible structure can make it harder to predict near-term health care costs.
