Explaining Health Savings Accounts in the Affordable Care Act Marketplaces

By Avni Gupta and Matt McGough   KFF

The 2025 federal budget reconciliation law (“The One Big Beautiful Bill Act” or “OBBBA”) aimed to promote the use of health savings accounts (HSAs) for Marketplace enrollees through a variety of provisions, including allowing all ACA-compliant individual market  bronze and catastrophic plans sold on and off the Affordable Care Act (ACA) Marketplaces to be HSA-eligible beginning in plan year 2026 regardless of their deductible, out-of-pocket maximum, or benefit design.

Previously, despite having high deductibles, catastrophic plans and most bronze plans did not meet the Internal Revenue Service’s (IRS) definition of a high-deductible health plan (HDHP) due to ineligible pre-deductible benefit coverage and/or their out-of-pocket maximums. The reconciliation law also expanded other HSA eligibility rules — allowing direct primary care arrangements and pre-deductible telehealth coverage in HSA-eligible plans.

This brief examines HSAs in the context of recent changes under the OBBBA to expand access to these HSA-eligible plans and accounts, with a focus on their potential implications for ACA Marketplace enrollees. The availability of plans compatible with an HSA has increased substantially since the implementation of relevant provisions from the OBBBA. This new environment comes with both benefits and risks for consumers. On the one hand, Marketplace enrollees could benefit from the tax advantages of contributing to an HSA. Additionally, some enrollees with incomes above four times poverty can potentially use tax-deductible contributions to an HSA to become eligible for premium tax credits. On the other hand, enrolling in HSA-eligible Marketplace coverage or contributing to an HSA means signing up for a high-deductible plan and could complicate consumer decisions by requiring them to anticipate future health care costs and income, and weighing health costs  against other short-term household spending.