The Affordable Care Act’s (ACA) enhanced premium tax credits are set to expire, and recent policy changes, including the expansion of hardship exemptions for catastrophic plans and changes to health savings account (HSA) eligibility, may significantly impact ACA Marketplace enrollment and affordability in 2026 and beyond. Bronze and catastrophic plans, which have lower premiums but higher deductibles, may become more appealing to consumers.
Bronze plans, one of the four “metal levels” of qualified health plans (QHPs), have the lowest premiums but the highest deductibles, with an average deductible of $7,476 in 2026. Catastrophic plans, which are a separate tier of QHPs, often have even lower premiums but higher cost-sharing, with deductibles equal to the out-of-pocket maximum allowed under the ACA ($10,600 for an individual or $21,200 for a family in 2026).
Recent changes include the expansion of catastrophic plan hardship exemptions to include consumers who are not eligible for premium tax credits or cost-sharing reductions due to their income. The Trump administration has also streamlined the application process for this hardship exemption and made it easier for consumers to enroll in a catastrophic plan. Additionally, all individual market bronze and catastrophic plans are now considered high-deductible health plans (HDHPs) and eligible to be paired with an HSA, even if they do not meet the minimum annual deductible requirement.
The availability and enrollment of bronze and catastrophic Marketplace plans vary. In 2026, catastrophic plans are offered in 36 states and the District of Columbia, and less than 1% of Marketplace enrollees chose a catastrophic plan in 2025. The average lowest-cost catastrophic Marketplace plan for a 27-year-old individual is $346 per month, a 29% increase from 2025, while the average lowest-cost unsubsidized bronze plan is $369 for a 27-year-old, a 19% increase from 2025.
The outlook for consumers is complex, with recent policy changes having wide-reaching implications for Marketplace coverage. The expiration of enhanced premium tax credits may lead to increased premiums, and some enrollees may switch to plans with higher deductibles or exit the Marketplace. Changes to HSA eligibility may also influence plan choices, with 35% of Marketplace plans sold on HealthCare.gov now HSA-eligible. However, higher-income individuals may benefit more from HSAs due to their higher tax brackets and greater ability to contribute to these accounts.
Consumers may face challenges in navigating the complex health insurance system, with limited understanding of plan options and potential marketing pitches that can compound the difficulties of making an informed decision. Price-sensitive consumers shopping for bronze and catastrophic plans may face difficult trade-offs, with higher deductibles and limited cost-sharing reductions. Many Marketplace enrollees already struggle to afford health care costs, and the recent changes may exacerbate these challenges.