To be eligible to open or contribute to a health savings account (HSA), an individual must (1) be covered by a qualified HDHP, (2) have no disqualifying health coverage, (3) not be enrolled in Medicare, and (4) not be claimed as a dependent on another person’s current-year tax return.
The OBBB introduces a major shift by automatically classifying all Bronze and Catastrophic plans offered on the Exchange as HDHPs for HSA purposes, even if these plans don’t meet the usual HDHP criteria. This expansion is particularly significant because many existing Bronze plans offer certain non-preventive benefits before the deductible is met, and many Catastrophic plans fail to align with required out-of-pocket maximum limits that previously disqualified them from HSA compatibility.
Employer Action Items
Update plan documents and enrollment materials to reflect expanded HSA eligibility, if desired, and consult with insurers and administrators of the group health plan and HSA regarding implementation of the changes for first-dollar telehealth coverage, HSA compatibility for all Exchange Bronze and Catastrophic plans, and inclusion of direct primary care arrangements starting in 2026.