Executive Summary
Prior to the One Big Beautiful Bill Act (OBBB), only some High-Deductible Health Plans (HDHPs) were considered Health Savings Account (HSA) eligible. Catastrophic health plans were not defined as HDHPs and were therefore, not HSA eligible. In 2025 only 2% of HealthCare.gov Marketplace enrollees selected HSA‑eligible plans-a sharp decline from 7% in 2020 (Centers for Medicare & Medicaid Services 2025a). Effective January 1, 2026, the OBBB reclassifies Bronze and Catastrophic ACA Marketplace plans as qualifying HDHPs, enabling millions more enrollees to open and contribute to HSAs without having to change insurance plans (Andrews, 2025). Approximately 30% of Marketplace enrollees selected Bronze plans during the 2025 OEP-an estimated 7.27 million people (Centers for Medicare & Medicaid Services 2025b). Catastrophic enrollment, while much smaller (54,000) because of highly restrictive enrollment criteria, adds to this total, making an additional 7.3 million Americans eligible for HSAs at current enrollment levels.
On September 3, 2025, the Centers for Medicare and Medicaid Services (CMS) announced changes to catastrophic enrollment processes that will further expand the number of Americans eligible for HSAs. Previously, catastrophic plans were restricted to those under 30 years old or individuals who qualify for a hardship exemption. CMS has expanded eligibility for those over 30 to qualify for catastrophic plans through the Obamacare law's hardship enrollment pathway. These expansions in catastrophic eligibility will likely increase enrollment by several million more. We estimate the additional enrollment of 3 million in catastrophic plans coupled with the expansion of HSA eligibility for bronze and catastrophic plans, will increase the number of Americans eligible for an HSA to 10 million.
