Executive Summary
Before the enactment of the One Big Beautiful Bill Act (OBBB), the realm of High-Deductible Health Plans (HDHPs) was rather exclusive, with few plans qualifying for Health Savings Accounts (HSAs). Catastrophic health plans, which weren’t recognized as HDHPs, found themselves on the outside looking in when it came to HSA eligibility. Fast-forward to 2025, and alarming statistics show only 2% of enrollees in the HealthCare.gov Marketplace had chosen HSA-eligible plans—a stark drop from 7% in 2020 (Centers for Medicare & Medicaid Services, 2025a). However, come January 1, 2026, the OBBB aims to shake things up by reclassifying both Bronze and Catastrophic ACA Marketplace plans as qualifying HDHPs. This pivotal change opens the floodgates for millions to establish and contribute to HSAs, all without the hassle of switching their insurance plans (Andrews, 2025). It’s noteworthy that around 30% of Marketplace enrollees opted for Bronze plans during the 2025 Open Enrollment Period (OEP)—translating to an estimated 7.27 million individuals (Centers for Medicare & Medicaid Services, 2025b). Although Catastrophic enrollment remains relatively minor at around 54,000 due to its stringent eligibility requirements, this demographic still contributes to a burgeoning pool—potentially adding 7.3 million more Americans who can now access HSAs based on current enrollment metrics.
On September 3, 2025, the Centers for Medicare and Medicaid Services (CMS) took a fortuitous step by altering catastrophic enrollment criteria, further widening the net of HSA eligibility for Americans. Initially, catastrophic plans were siloed off to those under 30 or those able to take shelter under a hardship exemption. Thanks to the new regulations, people over 30 can now enter this pool through the Obamacare law’s pathway for hardship enrollment. This expansion is poised to draw in additional millions. We project that the uplift in catastrophic enrollments will swallow up an extra 3 million individuals, alongside the expansions of HSA eligibility for both Bronze and Catastrophic plans, boosting the count of Americans eligible for HSAs to a significant 10 million.
