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Open enrollment is here, and the cheapest plan on the Exchange is a bronze plan. Until this year that was a problem for anyone who wanted a health savings account. HSA eligibility changed in July 2025, and in January the IRS issued Notice 2026-5 to spell out how.
HSA Eligibility Changes for 2026 and 2027
Does a bronze or catastrophic plan qualify for an HSA now?
Many do. Under Notice 2026-5, a bronze or catastrophic plan bought through an ACA Exchange counts as a high-deductible health plan for months starting after December 31, 2025. A plan bought off the Exchange counts too, when the same plan is sold on it. SHOP Exchange coverage is left out.
Picture a single filer with a bronze plan and a $7,000 deductible. Last year that filer often could not fund an HSA. This year the filer can, for every month the plan is in force.
Can you use telehealth without losing HSA eligibility?
Yes. A free telehealth visit before the deductible is met no longer costs you the account. The rule is permanent. It covers plan years that begin after December 31, 2024.
Does direct primary care block an HSA?
No, if the fee stays under the cap. The cap is $150 a month for one person and $300 a month for more than one person. It adjusts for inflation after 2026.
How much can you contribute to an HSA in 2027?
Revenue Procedure 2026-24 sets the 2027 limits at $4,500 for self-only coverage and $9,000 for family coverage. The catch-up amount and the FSA figures are in our 2027 HSA limits guide.
Editor’s Take
Bronze plans carry the highest deductibles on the Exchange, so an HSA pairs with them naturally. That is the point of the change. A lower premium only helps if you can pay the deductible, and an HSA balance is how many people will. Read the plan’s summary of benefits and look for the words HSA-qualified. Our ACA open enrollment guide has the deadlines, and HSA eligibility should be on your checklist before you enroll.
