Expansion of HSA Eligibility Under OBBB Act to Improve Marketplace Coverage, Affordability, and Access
9/26/2025
Action Summary
- Purpose: Expand HSA eligibility under the OBBB Act to boost marketplace coverage, affordability, and access.
- Eligibility Expansion: Reclassification of Bronze and Catastrophic ACA Marketplace plans as qualifying HDHPs effective January 1, 2026, thereby allowing millions to contribute to HSAs without changing plans.
- Current Enrollment Data: In 2025, only 2% of Marketplace enrollees selected HSA‑eligible plans, a significant decline from 7% in 2020. Approximately 30% selected Bronze plans, representing around 7.27 million individuals, plus an additional 54,000 from Catastrophic plans.
- CMS Adjustments: On September 3, 2025, CMS expanded catastrophic plan eligibility to include individuals over 30 via an Obamacare hardship pathway, previously limited to under-30s or those qualifying for a hardship exemption.
- Projected Impact: These combined changes are expected to increase the number of Americans eligible for an HSA to nearly 10 million.
Risks & Considerations
- The expansion of Health Savings Account (HSA) eligibility under the One Big Beautiful Bill Act (OBBB) could lead to increased complexity in health insurance choices for students and staff at Vanderbilt University. This may require additional resources to educate the university community about these changes.
- With the reclassification of Bronze and Catastrophic ACA Marketplace plans as qualifying High-Deductible Health Plans (HDHPs), there is a potential risk of confusion among enrollees regarding their eligibility and benefits, which could impact their healthcare decisions and financial planning.
- The increase in the number of Americans eligible for HSAs may lead to a shift in the healthcare market, potentially affecting the cost and availability of health services that Vanderbilt University Medical Center provides or partners with.
- Vanderbilt University may need to assess the impact of these changes on its employee health benefits offerings, particularly if a significant portion of its staff opts for HSA-eligible plans.
Impacted Programs
- Vanderbilt University Medical Center may need to adjust its billing and insurance processes to accommodate the increased use of HSAs by patients, ensuring that services are accessible and affordable.
- The Human Resources Department at Vanderbilt may need to provide additional support and resources to employees navigating the new HSA eligibility landscape, including workshops or informational sessions.
- Student Health Services might experience changes in the types of insurance plans students use, necessitating updates to their billing systems and financial counseling services.
- The School of Medicine could see increased demand for research and expertise in health policy and insurance, presenting opportunities for collaboration with federal agencies and healthcare organizations.
Financial Impact
- The expansion of HSA eligibility could lead to changes in the financial planning and healthcare spending patterns of Vanderbilt’s employees and students, potentially affecting the university’s health benefits costs and offerings.
- Vanderbilt University may need to invest in educational resources and support systems to help its community understand and maximize the benefits of HSAs, which could incur additional costs.
- There may be opportunities for Vanderbilt to engage in research and policy analysis related to the impacts of expanded HSA eligibility, potentially attracting funding and partnerships with government and private entities.
- The increased use of HSAs could influence the demand for certain healthcare services, impacting the revenue streams of Vanderbilt University Medical Center and affiliated clinics.
Relevance Score: 3 (The changes present moderate risks involving compliance and potential impacts on healthcare services and financial planning.)
Key Actions
- Vanderbilt’s Health Policy Department should analyze the implications of the expanded HSA eligibility under the OBBB Act. This analysis can help identify potential impacts on healthcare access and affordability for students and staff, and guide the university in adjusting its health benefits offerings accordingly.
- The Office of Financial Aid should consider the potential financial benefits of HSAs for students and staff. By providing information sessions or workshops on how to effectively use HSAs, the university can enhance financial literacy and support the financial well-being of its community.
- Vanderbilt’s Medical Center could explore partnerships with insurance providers to offer HSA-eligible plans to employees, leveraging the expanded eligibility to provide more flexible and cost-effective healthcare options.
- The Department of Economics should conduct research on the economic impacts of the expanded HSA eligibility, particularly how it affects healthcare spending and consumer behavior. This research can contribute to broader policy discussions and enhance Vanderbilt’s reputation as a leader in health economics.
Opportunities
- The expansion of HSA eligibility presents an opportunity for Vanderbilt’s School of Medicine to develop educational programs focused on the benefits and management of HSAs. By educating future healthcare professionals on these financial tools, the university can prepare them to better advise patients on managing healthcare costs.
- Vanderbilt can capitalize on the increased HSA eligibility by offering targeted financial planning services to students and staff. This could include personalized consultations or online resources to help individuals maximize the benefits of their HSAs.
- The university can engage in policy advocacy by collaborating with other institutions to influence future healthcare reforms. By leveraging its research and expertise, Vanderbilt can play a significant role in shaping policies that promote healthcare access and affordability.
Relevance Score: 3 (Some adjustments are needed to processes or procedures to align with the expanded HSA eligibility and its potential impacts on the university community.)
Timeline for Implementation
- Effective January 1, 2026
This timeline was identified based on the directive stating the reclassification effective date for Bronze and Catastrophic ACA Marketplace plans.
Relevance Score: 2
Impacted Government Organizations
- Centers for Medicare & Medicaid Services (CMS): CMS is directly involved in the implementation of changes to catastrophic enrollment processes and the reclassification of Bronze and Catastrophic ACA Marketplace plans as qualifying High-Deductible Health Plans, thereby expanding HSA eligibility.
Relevance Score: 1 (Only one federal agency is directly impacted by this directive.)
Responsible Officials
- Centers for Medicare & Medicaid Services (CMS) – Responsible for implementing the reclassification of ACA Marketplace Bronze and Catastrophic plans as qualifying HDHPs and managing the expanded catastrophic enrollment processes.
Relevance Score: 4 (Directives affect agency heads and are implemented at the highest levels within CMS.)