As Congress debates whether to extend the enhanced subsidies for Affordable Care Act (ACA) coverage, some lawmakers are proposing an alternative: expanding the use of HSAs or even redirecting a portion of ACA subsidy funding into account-based assistance. With this change to ACA coverage, support would be moved from upfront premium assistance to individual savings accounts managed by each consumer.
At their core, HSAs are tax-advantaged savings accounts that allow individuals to set aside pre-tax dollars to pay for qualified medical expenses. These contributions reduce taxable income, allow earnings in the account to grow tax free, and keep withdrawals for eligible costs from being taxed. Unlike other benefit accounts, HSA balances roll over year to year and belong entirely to the individual, who must be enrolled in a high-deductible health plan (HDHP), a plan with lower monthly premiums and higher upfront costs.
The ACA and HSAs both aim to make health care more affordable but in different ways — by lowering costs at the point of purchase or offering flexibility in how expenses are paid over time. Historically, few ACA marketplace plans met those federal criteria, meaning most enrollees couldn’t contribute to an HSA. But a significant change to marketplace plans is creating new discussions around HSAs and ACA subsidy funding.
A Shift Toward Account-Based Assistance
Beginning in 2026, all Bronze and Catastrophic marketplace plans will qualify as eligible for HSAs under new federal rules, potentially opening the door for more Americans to pair tax-advantaged savings with ACA coverage. Bronze plans are lower-premium options with higher deductibles and cost sharing, typically chosen by consumers who prefer to pay less each month and can manage higher upfront expenses when they need care. Catastrophic plans, available mainly to people under 30 or those with financial hardship exemptions, have even higher deductibles and are designed to protect against major medical costs rather than routine care.
With more plans becoming eligible, lawmakers are considering whether these accounts could serve not only as individual savings tools but also as vehicles for delivering federal affordability assistance. In Congress, some lawmakers have proposed that rather than continuing to direct subsidies toward lowering monthly premiums, some or all of these funds would be redirected to HSAs. The idea is that consumers would have greater control over their health care dollars by allowing them to decide whether to use the funds for premiums, out-of-pocket costs, or other qualified expenses.
This discussion has prompted some analysts to examine how such a change might affect the structure and stability of the ACA marketplace. They note that replacing or reducing those credits with HSA-based assistance could change how consumers enter and stay in the marketplace, potentially rewarding those who can save in advance while making coverage less predictable for others. They also caution that if healthier individuals choose lower-cost, HSA-compatible plans while others stay in more comprehensive coverage, premiums could rise for those who remain.
From Policy to Implementation
For policymakers, the path forward may not be about choosing between HSAs and ACA subsidies but about sequencing, ensuring that operational readiness and consumer stability come first. If Congress were to approve the new account-based model, ACA systems would need to be significantly reconfigured, and it is likely that new rules would be needed from the Centers for Medicare & Medicaid Services (CMS). Another immediate challenge is timing: open enrollment began on November 1, during a partial government shutdown, and ends in most states on December 15, which leaves consumers only a few weeks to select or renew coverage. The implementation of an updated ACA system could take months or a full plan year, underscoring the difficulty of altering subsidy structures at this stage.
Regardless, any effort to realign affordability tools must prioritize continuity for consumers by modernizing the system without compromising access during the transition. At GetInsured, we see firsthand how policy decisions translate into real-world system demands. The success of any reform – whether it involves HSAs, enhanced tax credits, or new affordability models – depends on the ability to implement those changes quickly and accurately. Our focus remains on building technology that can adapt to evolving policy so that no matter how the landscape shifts, consumers can access coverage that is simple, reliable, and within reach.
