2026 Health Plan Game-Changer: 3 ACA Rule Changes That Maximize Your ICHRA Savings

If you're researching Individual Coverage Health Reimbursement Arrangements (ICHRAs), you've probably encountered the intense debate surrounding the Affordable Care Act (ACA) individual health insurance markets. While the expiration and potential extension of the enhanced Advanced Premium Tax Credits (APTCs) are dominating the headlines and have recently played a role in the government shutdown debate there are three significant regulatory changes taking effect this year that deserve your attention and could save you money.

1. All Bronze and Catastrophic Plans Are Now Health Savings Account (HSA)-Eligible

Starting in 2026, every Bronze and Catastrophic plan sold on the exchange automatically qualifies for a Health Savings Account. This is a big deal.

Previously, you had to hunt for specific High-Deductible Health Plans to get HSA eligibility. Now, if you're looking at any Bronze or Catastrophic coverage on Healthcare.gov or a state-based exchange like Covered California, you can pair it with an HSA. Some states even offer Bronze plans with zero deductibles, which means you can access HSA savings without needing a high-deductible plan at all.

Read more in our detailed guide.

2. Catastrophic Plans Are Available to More People

Catastrophic plans have always offered the lowest monthly premiums, but they were essentially locked to people under 30. or people with a financial hardship exemption.

That's changing.

You now automatically qualify for a hardship exemption if your income makes you ineligible for government financial assistance on the Marketplace. This typically includes:

• High-Income Consumers: People whose household income is above 400% of the Federal Poverty Level (FPL) and lose their premium subsidies (APTCs) due to the return of the "subsidy cliff."
• Low-Income Consumers: People whose income is below 100% of the FPL and are therefore ineligible for APTCs in many states.
• Mid-to-High Income Consumers: People with incomes above 250% of the FPL who are ineligible for Cost-Sharing Reductions (CSRs), making even subsidized plans unaffordable.

3. The Off-Exchange Market Is Worth a Look

Most ICHRA shopping happens on the marketplace, but the off-exchange market has quietly become more competitive.

In response to demand, carriers are adding off-exchange plans with broader provider networks and richer benefits than what's available on the exchange. Since ICHRA participants can shop anywhere, you're not limited to marketplace plans.

If you need a specific doctor or specialist, or if you've found the exchange networks too restrictive, check what's available off-exchange. You might find better network access for a comparable premium.

The Bottom Line

Take a serious look at Bronze and Catastrophic plans, especially if you've been avoiding them because they weren't HSA-eligible before. With all marketplace Bronze and Catastrophic plans now HSA-qualified, you have more options than ever to stretch your ICHRA dollars.

Run the numbers on how much of your ICHRA allowance you'd save with a lower-premium plan, and whether that savings could go into an HSA. If you're over 30 and healthy, find out if you qualify for a Catastrophic plan under the expanded hardship criteria. And don't limit yourself to the marketplace. Spend 15 minutes checking off-exchange plans to see if you can get better network access at the same cost.

Open Enrollment doesn't last forever. Make sure your ICHRA is working as hard as possible for you.