More health insurance plans will work with health savings accounts (HSAs) in 2026.
Internal Revenue Service (IRS) Notice 2026-5, which explains how the federal government will handle HSA changes created in the One Big Beautiful Bill Act (OBBBA)1, now treats bronze and catastrophic policies as HSA-compatible health plans, even if they don’t meet traditional high deductible health plan (HDHP) thresholds.
This change opens the door for more employees, especially those using an individual coverage health reimbursement arrangement (ICHRA), to combine lower premiums with tax-advantaged savings.
In this article, you’ll learn:
Under Internal Revenue Code §223, individuals can only contribute to a health savings account (HSA) if they’re enrolled in a qualified HDHP2.
For 2026, the IRS defines an HDHP3 as a plan with at least:
However, starting January 1, 2026, IRS Notice 2026-5 allows bronze and catastrophic plans on the individual market to be treated as HDHPs for HSA eligibility, even if their deductibles are below the standard minimums. This is referred to as “deemed HDHP” status.
While anyone can enroll in a bronze plan, catastrophic plans have had limited eligibility. They were generally available to individuals younger than age 30 or those with a hardship exemption4.
For 2026, eligibility expands. Individuals who aren’t eligible for Marketplace premium subsidies due to income may qualify to enroll in catastrophic coverage, if those plans are available in their area.
If you’re considering one of these plan types, here’s how they compare5:
|
Key features |
Bronze plans |
Catastrophic plans |
|
Availability |
Widely available |
Not available in all states or rating areas |
|
Plan options |
Multiple carrier options |
Limited options (often 1–2 plans) |
|
Monthly premiums |
Low premiums |
Often low premiums, but may be higher than bronze in some markets |
|
Services before deductible |
May cover certain services before the deductible |
Covers three primary care visits before the deductible |
|
Eligibility for premium tax credits |
Yes, if eligible |
No |
Notice 2026-5 doesn't limit HSA eligibility6 to plans purchased through HealthCare.gov or a state Marketplace.
The IRS states that off-exchange bronze plans may also qualify, provided the coverage is “substantially the same”7 as the on-exchange bronze plan version.
This clarification is especially important for:
If the off-exchange plan mirrors an exchange bronze offering, it may receive the same “deemed HDHP” treatment for HSA purposes.
A health savings account (HSA) is a tax-advantaged savings account that individuals use to pay for qualified medical expenses.
To contribute, you must have an HSA-compatible health plan and meet IRS eligibility requirements. You, your employer, or both can contribute up to the annual IRS limit.
HSA funds:
Qualified expenses outlined in IRS Publication 502 include8:
HSAs offer a triple tax advantage: tax-deductible contributions, tax-free interest earnings, and tax-free withdrawals for IRS-qualified medical expenses.
The IRS released 2026 health savings account (HSA) limits in Revenue Procedure 2025-19.9
|
Coverage type |
2026 HSA contribution limit |
Catch-up (Age 55+) |
|
Self-only |
$4,400 |
+$1,000 |
|
Family |
$8,750 |
+$1,000 |
The IRS adjusts these amounts annually for inflation.
After signing up for an HSA-compatible health plan, individuals can open an HSA10 through a bank, credit union, or other approved financial institution. Many HSA administrators also offer investment options once the account reaches a certain balance threshold. Keep in mind that an employer offering HSA contributions may require employees to open an HSA through a partner institution or vendor.
For employers offering an ICHRA, this update is significant. Historically, employees who used their ICHRA allowance to purchase bronze coverage couldn’t contribute to an HSA unless the plan met HDHP requirements on its own. In 2026, employees can now use their ICHRA allowance to buy a bronze plan and still contribute to their own HSA (if the ICHRA plan design allows it).
An ICHRA can work alongside an HRA as long as the employer offers a limited-purpose ICHRA (premium-only) or a post-deductible ICHRA to any individuals participating in an HSA. The ICHRA Final Rules even allow employers to give employees a choice between an HSA-compatible ICHRA and a non-HSA-compatible ICHRA within the same employee class, giving employees the option to participate in an HSA or not.
This creates a powerful combination:
For employers modernizing their benefits strategy, this change increases flexibility without sacrificing tax efficiency.
IRS Notice 2026-5 expands access to health savings accounts (HSAs) in the individual market. By granting deemed HDHP status to bronze and catastrophic plans, including qualifying off-exchange options, the IRS has created new flexibility for employees who want lower monthly premiums without giving up tax-advantaged savings opportunities. For employers offering ICHRAs, this strengthens the value of a defined-contribution health benefit.