HSA Eligibility Changes: What to Know Before Open Enrollment
If you run a small business or work for yourself, you may be preparing for Affordable Care Act (ACA) marketplace open enrollment this fall. Business owners and the self-employed account for roughly 28% of working-age marketplace enrollment.
Most people in this position are also their own benefits department. There is no HR team to walk through the options during open enrollment, and no enrollment specialist to follow up with.
That’s worth keeping in mind this year in particular, because eligibility rules changed in a way that affects the plans this group buys most, and the change is easy to miss.
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What changed
Starting in 2026, enrollment in a Bronze or Catastrophic plan through the ACA marketplace makes an individual eligible to contribute to a health savings account (HSA). That’s true even for Bronze or Catastrophic plans that don’t meet the IRS definition of a high-deductible health plan (HDHP), which was previously the only avenue to funding an HSA.
More than seven million people fall into this newly eligible category, making it the largest expansion of access to HSAs to date.
The newly eligible group is also growing. For 2026 coverage, nearly 9.2 million marketplace enrollees selected Bronze plans — nearly 40%, up from roughly 30% the year before — as many buyers moved to the lowest-premium tier when enhanced federal premium subsidies expired.
How an HSA can help your finances
First, the limitation: An HSA can’t be used to pay insurance premiums, which many Bronze-plan enrollees saw increase substantially this year with the end of the enhanced ACA subsidies. If premiums are where your budget hurts most, an HSA does not address that directly.
What an HSA can do is reduce the after-tax cost of the healthcare you pay for out of pocket. If you chose a Bronze plan, out-of-pocket costs are precisely the trade-off you accepted: A lower premium in exchange for a higher deductible.
An HSA is built for that structure. No other type of account, whether for spending or investing or both, offers the combination of:
- In most states, no taxes on funds added to the account
- No taxes on growth within the account (whether bank interest or investment returns)
- No taxes on withdrawals from the account, so long as funds are used for qualified healthcare expenses
Here is a simplified example for someone who pays income tax. Say you add $1,000 to your HSA for the 2027 calendar year, and this $1,000 is part of your overall income that would otherwise be subject to income tax. When you use that $1,000 to pay for healthcare expenses, you have the full $1,000 available.
Contrast that with paying a $1,000 healthcare bill from ordinary funds. In that case, you would have needed to earn more — say, $1,100 or $1,200, depending on your tax rate — to pay the same bill. You are functionally reducing your healthcare expenses by $100 or $200. For someone who is self-employed, that difference comes straight out of the income the business generates.
There is also no “use it or lose it” provision with HSAs. The balance in your HSA can grow year over year, which is why the tax-free growth can become more significant over multiple years of contributions.
Open enrollment elections
Open enrollment for 2027 marketplace coverage runs November 1 through December 15 in most states — a shorter window than in past years. If you are shopping for Bronze and Catastrophic plans, the plan information will note that HSAs are permitted.
However, insurers generally don’t promote that fact, and most state and federal exchange sites are only beginning to incorporate HSA guidance. For those buying coverage on their own, knowing the option exists is the first step.
Putting an HSA to work
You can open and set up an account with a qualified custodian, typically a bank. In 2027, the maximum contribution is $4,500 for individuals and $9,000 for those with family coverage, plus an extra $1,000 if you are 55 or older.
If you contribute on your own, you report those contributions when you file your taxes, and the amount nets off your income — reducing taxes due or increasing your refund.
Balances can be spent on qualified medical expenses for you and your covered dependents, including telehealth services and — new this year — fees for direct primary care arrangements, up to an IRS monthly limit.
Be sure to keep your receipts because you can reimburse yourself for a qualified expense even years after incurring it, allowing the account to grow tax-free in the meantime.
With steady contributions, you may eventually build a balance larger than your plan’s annual out-of-pocket maximum. At that point, you may want to consider shifting some of your HSA into investments with the potential to grow faster than bank interest.
The process is similar to making choices within a 401(k) plan, subject to your custodian’s options and minimums.
For a business owner or self-employed professional without access to a workplace retirement plan’s full toolkit, an HSA used this way becomes a second tax-advantaged savings channel that’s specifically matched to a category of expense that tends to grow later in life.
Healthcare costs are a fact of running your own working life. For the millions who became HSA-eligible this year, the account won’t solve the premium problem, but it is a durable tool for the costs that come after the premium. This open enrollment season is the natural time to put it to work.
