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Bronze and Catastrophic Plans Now Qualify for an HSA: What It Means for Houston in 2027

If you picked a bronze plan on the Marketplace for 2026, there is a fair chance nobody mentioned the tax account that now comes with it. For years, most bronze plans could not be paired with a health savings account. The out-of-pocket maximum ran past the IRS limit, or the plan paid for an office visit before the deductible. Either one shut the door.

That door opened on January 1, 2026. A provision of Public Law 119-21 — the federal tax law signed July 4, 2025 and commonly called the One, Big, Beautiful Bill Act — now treats bronze and catastrophic plans as HSA-compatible high-deductible health plans, whether or not they meet the usual deductible and out-of-pocket tests. The IRS explained the details in Notice 2026-5.

With 2027 Open Enrollment opening November 1, 2026, this belongs in your plan decision. For some Houston households, bronze with an HSA is a sensible pairing. For others — especially families who qualify for cost-sharing reductions on a silver plan — it can be the wrong trade. Below: what changed, which plans count, the numbers, three worked examples, and a checklist.

217,208

Harris County residents who selected a bronze plan for 2026 — a plan type the IRS now treats as compatible with a health savings account. Another 89 chose catastrophic plans, which also qualify.

CMS 2026 OEP County-Level Public Use File · IRS Notice 2026-5

The short answer: yes, a bronze plan can now work with an HSA. For months beginning after December 31, 2025, any bronze or catastrophic plan available as individual coverage through an Exchange counts as a high-deductible health plan for HSA purposes. If you have no other disqualifying coverage, are not enrolled in Medicare, and cannot be claimed as someone else’s dependent, you can contribute up to $4,400 (self-only) or $8,750 (family) for 2026, and $4,500 or $9,000 for 2027 — plus $1,000 if you are 55 or older.

Key Takeaways
  • Bronze and catastrophic plans have counted as HSA plans since January 1, 2026, even when their deductible or out-of-pocket maximum falls outside the normal HDHP limits.
  • Off-Exchange can count too, if the same plan is sold on an Exchange. Bronze coverage through a small employer’s SHOP program generally does not.
  • 2027 HSA limits are $4,500 self-only and $9,000 family under IRS Rev. Proc. 2026-24, plus a $1,000 catch-up at 55.
  • Direct primary care memberships no longer block contributions when fees stay at or under $150 a month for one person or $300 for more than one.
  • Cost-sharing reductions still come only with silver plans. Between 100% and 250% of the poverty line, silver can cap a family’s 2027 cost sharing at $8,000 or $19,200 instead of $24,000.
  • Catastrophic plans work with an HSA but not with a premium tax credit, and the 2027 expansion of who may buy one was stayed by a federal court on July 16, 2026.
  • 2027 Open Enrollment runs November 1, 2026 through January 15, 2027. Enroll by December 15 for coverage — and HSA eligibility — starting January 1.

What changed on January 1, 2026

A health savings account is a personal account for medical costs. Money goes in deductible or excluded from pay, grows without yearly tax, and comes out tax-free when spent on qualified medical expenses. The catch has always been the plan attached to it: only people covered by a high-deductible health plan, or HDHP, may contribute.

An older couple smiles over a tablet together on a living room sofa.
Choosing between a bronze plan with an HSA and a silver plan with cost-sharing reductions is a household decision. It turns on expected income, savings on hand and how much out-of-pocket risk you can carry until Medicare or the next Open Enrollment.

The tax code defines an HDHP precisely. For 2026, IRS Rev. Proc. 2025-19 requires a deductible of at least $1,700 for self-only coverage and caps out-of-pocket costs at $8,500. The plan also generally cannot pay for care other than preventive services before the deductible.

Marketplace bronze plans are built to a different ceiling: the ACA’s limit on cost sharing, which was $10,600 for self-only coverage in 2026 and rises to $12,000 for 2027, according to CMS guidance dated January 29, 2026. A hypothetical bronze plan with a $10,000 out-of-pocket maximum was perfectly legal — and failed the HSA test by $1,500. As Notice 2026-5 puts it, “many bronze plans did not qualify as HDHPs because the plans’ out-of-pocket maximum exceeded the statutory limits for HDHPs or because they provided benefits that were not preventive care without a deductible.” Catastrophic plans never qualified, because the ACA requires them to cover at least three primary care visits before the deductible.

Section 71307 of the law added subparagraph (H) to 26 U.S.C. 223(c)(2): a high-deductible health plan now “shall include any plan which is — (i) available as individual coverage through an Exchange” and is a bronze or catastrophic plan under the ACA. The IRS says it “applies for months beginning after December 31, 2025,” so January 2026 was the first eligible month. Pre-deductible benefits no longer matter either; a Notice 2026-5 footnote states that “Bronze plans are treated as HDHPs under section 223 regardless of which services they cover before the deductible.”

Which plans qualify, and which do not

The statute says “available as individual coverage through an Exchange.” That raised an obvious question for anyone who buys straight from an insurer rather than through the federal Marketplace Texas uses. The IRS answered it, along with several edge cases.

Your coverageTreated as an HSA plan?Basis
Bronze plan bought on the MarketplaceYes, for months after December 2025Notice 2026-5, Q&A-4
Catastrophic plan bought on the MarketplaceYesQ&A-4
Bronze or catastrophic plan bought off-Exchange, when the same plan is sold on an ExchangeYes, including off-Exchange versions priced without the cost-sharing reduction loadQ&A-6
Off-Exchange bronze or catastrophic plan you have no reason to think is unavailable on an ExchangeThe IRS will treat you as eligibleQ&A-7
Bronze plan paid for with an individual coverage HRA from your employerYes; using the HRA does not remove HDHP statusQ&A-5
Bronze plan variant with American Indian and Alaska Native cost-sharing reductionsYes, even if its actuarial value tops 60%Q&A-9
Bronze plan offered through a small employer’s SHOP coverageGenerally no, unless it passes the standard HDHP testsQ&A-8
Silver plan, including a cost-sharing reduction variantOnly if it passes the standard HDHP tests on its own26 U.S.C. 223(c)(2)(H) names bronze and catastrophic plans only
Gold or platinum planOnly if it passes the standard HDHP testsSame

Two rows deserve a closer look. The employer HRA row carries a caveat in Q&A-5: an HRA generally must reimburse only premiums, or it becomes other coverage that can disqualify you. Our employer health insurance page explains how these arrangements work.

And silver: the new subparagraph reaches bronze and catastrophic plans and nothing else. A silver plan, including the reduced cost-sharing versions, counts only if it independently meets the standard HDHP definition — for 2027, a deductible of at least $1,750 for self-only coverage and out-of-pocket costs no higher than $8,700. Confirm the HSA status of the specific plan before you enroll.

The 2026 and 2027 numbers in one place

The IRS published the 2027 figures in Rev. Proc. 2026-24 in May 2026. Here they are beside the 2026 amounts and the ACA limits that bronze plans are built around.

Item20262027Applies to bronze or catastrophic plans?
HSA contribution limit, self-only coverage$4,400$4,500Yes
HSA contribution limit, family coverage$8,750$9,000Yes
Catch-up contribution, age 55 or older$1,000$1,000Yes
Standard HDHP minimum deductible (self-only / family)$1,700 / $3,400$1,750 / $3,500No — the test is waived
Standard HDHP out-of-pocket cap (self-only / family)$8,500 / $17,000$8,700 / $17,400No — the test is waived
Marketplace out-of-pocket limit (self-only / other)$10,600 / $21,200$12,000 / $24,000Yes, as a plan design ceiling
Direct primary care fee ceiling per month (one person / more than one)$150 / $300$150 / $300Yes, to keep contributing

What does not drop out is the Marketplace ceiling: a 2027 bronze plan may carry out-of-pocket costs up to $12,000 for one person and $24,000 for a family. A provision that would have let bronze plans exceed that ceiling was stayed in July, so those limits hold for 2027.

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Already on a 2026 bronze plan? Do not wait for January If you have been on bronze since January and meet the other rules, you may have been HSA-eligible all year. Contributions for a tax year can generally be made up to that year’s federal filing deadline — IRS Publication 969 gives April 15, 2026 for 2025 contributions. But “expenses incurred before you establish your HSA aren’t qualified medical expenses,” so opening the account now matters more than funding it all at once.

You still have to be an eligible individual

The law changed which plans count, not who counts. IRS Publication 969 lists the requirements, and all of them still apply:

  • You are covered under the qualifying plan on the first day of the month. Eligibility is tested month by month.
  • You have no other health coverage except permitted coverage such as dental, vision, accident, disability and long-term care insurance. A general-purpose health FSA or HRA that could pay your medical bills generally disqualifies you — so if a spouse has one at work, check whether it covers you.
  • You are not enrolled in Medicare. “Beginning with the first month you are enrolled in Medicare, your contribution limit is zero,” including periods of retroactive coverage.
  • No one else can claim you as a dependent. A 24-year-old whose parents still claim them does not qualify, even on the right plan.

Starting coverage mid-year, or late in the year

If you are not eligible for the full year, the limit is generally prorated — roughly one-twelfth of the annual amount for each month you were eligible on the first day. The exception is the last-month rule: “if you are an eligible individual on the first day of the last month of your tax year (December 1 for most taxpayers), you are considered an eligible individual for the entire year.” The price is a testing period through the end of the following year. Lose eligibility during it, for reasons other than death or disability, and the extra contributions become taxable income “also subject to a 10% additional tax.”

That makes enrollment timing a tax question too. Per the federal Marketplace calendar for 2027 coverage, a plan chosen by December 15 starts January 1; one chosen between December 16 and January 15 starts February 1. Pick bronze on January 10, and January is not an eligible month.

If you are approaching Medicare

Medicare.gov is direct: “you and your employer should stop contributing to your HSA 6 months before you retire or apply for benefits from Social Security.” Our walkthrough of the HSA six-month rule for Houston workers covers the timing, and our Medicare eligibility page explains when coverage can begin.

Direct primary care and telehealth

Direct primary care

Direct primary care is a membership model: a flat periodic fee to a practice for a set of primary care services. The IRS generally treated that as a health plan paying before the deductible, which blocked HSA contributions. For months beginning after December 31, 2025, section 71308 says a qualifying arrangement no longer counts as one, and your HSA can pay its fees tax-free. The definition is tight.

RequirementWhat it means in practice
Primary care onlyCare from physicians in family, internal, geriatric or pediatric medicine, or from nurse practitioners, clinical nurse specialists or physician assistants
Excluded servicesProcedures requiring general anesthesia, prescription drugs other than vaccines, and lab services not typically done in an ambulatory primary care setting
Fixed fee is the only payIf the practice also bills insurance or you for services covered by the membership, it is not a qualifying arrangement (Q&A-11)
Fee ceilingTotal fees at or under $150 a month for one person, or $300 for an arrangement covering more than one, for both 2026 and 2027
Longer billing periodsAllowed up to a year if the annualized amount stays within the ceiling — for example $1,800 a year for one person in 2026 (Q&A-13)
The contract decides, not your usageSkipping services outside the definition does not turn a broader arrangement into a qualifying one (Q&A-14)

Three details trip people up. Fees above the ceiling can still be reimbursed from an HSA, but they “disqualify the covered individual from eligibility for making HSA contributions while the individual is enrolled” (Q&A-20). Membership fees do not count toward your bronze deductible or out-of-pocket maximum (Q&A-16). And fees your employer pays, including through salary reduction, cannot also be reimbursed from your HSA (Q&A-18).

Telehealth

Section 71306 made permanent the temporary rule letting an HDHP cover telehealth before the deductible. Notice 2026-5 says it “applies retroactively for plan years beginning after December 31, 2024.” It covers services on the Medicare telehealth list and similar remote care, not in-person services, equipment or drugs furnished alongside a virtual visit.

Who this helps, and who should look at silver first

An HSA is a tax break, and tax breaks are worth the most to people who owe tax and have cash to set aside. A bronze plan is a bet that you will not need much care. The pairing tends to suit households with steady savings, modest expected medical use, and incomes above the strongest cost-sharing reductions.

Cost-sharing reductions are the counterweight. They lower deductibles, copays and out-of-pocket maximums, and CMS guidance states that enrollees “must be enrolled in a silver plan variant to be eligible for CSRs.” Choose bronze for an HSA and you give them up. Our comparison of cost-sharing reductions on silver versus bronze goes deeper; the table uses the 2026 HHS poverty guidelines, which apply to 2027 coverage.

Household income (% of poverty line)1 personFamily of 42027 silver out-of-pocket limit (self / family)Where bronze plus an HSA tends to land
100% to 150%$15,960 – $23,940$33,000 – $49,500$4,000 / $8,000Usually outweighed by silver cost-sharing reductions and little tax to offset
Over 150% to 200%$23,940 – $31,920$49,500 – $66,000$4,000 / $8,000Silver usually deserves the first look
Over 200% to 250%$31,920 – $39,900$66,000 – $82,500$9,600 / $19,200A closer call; compare total costs plan by plan
Over 250% to 400%$39,900 – $63,840$82,500 – $132,000No reduction: $12,000 / $24,000A stronger case, and the premium tax credit still applies
Above 400%Above $63,840Above $132,000No reduction: $12,000 / $24,000No premium tax credit; the deduction is worth more at higher brackets

Dollar ranges are our arithmetic on the guidelines for the 48 contiguous states; silver limits are from CMS. Treat the last column as a starting point, not a verdict.

The deduction can move your premium tax credit

An HSA deduction lowers adjusted gross income, which under 26 U.S.C. 36B(d)(2) is the starting point for the household income the premium tax credit uses. HealthCare.gov lists “Health Savings Account (HSA) deposits (in limited situations)” among deductions that can reduce reported income. Near the 400% line, that can decide whether you get a credit at all — see our article on the 400% subsidy cliff.

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If you choose bronze to lower your premium, estimate income carefully IRS Fact Sheet 2025-10 is blunt: “There is no repayment cap for tax years after 2025.” If income comes in higher than estimated, the full excess credit comes off your refund or adds to your balance due. Our guide to reporting income changes to the Marketplace shows how to keep the estimate current.

The catastrophic plan catch

Catastrophic plans also qualify, and on paper they suit a young, healthy saver. Three facts narrow the fit.

No premium tax credit. Under 26 U.S.C. 36B(c)(3)(A), a qualified health plan for the credit “shall not include a qualified health plan which is a catastrophic plan described in section 1302(e).” HealthCare.gov’s catastrophic plan page notes that people who qualify for premium tax credits may find a bronze or silver plan a better value.

Limited eligibility. You must not have turned 30 before the plan year begins, or you must hold an affordability or hardship exemption. For 2027 the affordability exemption uses a required contribution percentage of 8.50%, up from 8.05%, per CMS.

A very high threshold. Apart from preventive care and at least three primary care visits, a catastrophic plan generally pays for essential benefits only after you reach the maximum cost sharing — $12,000 for self-only coverage in 2027.

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Catastrophic eligibility did not expand for 2027 The 2027 Payment Notice would have widened who may buy a catastrophic plan, raised catastrophic cost sharing and let bronze plans exceed the out-of-pocket ceiling. On July 16, 2026, in City of Columbus v. Kennedy, No. 1:26-cv-02215, the U.S. District Court for the District of Maryland stayed all three, along with related guidance issued September 4, 2025. The CMS statement of July 31, 2026 lists them among provisions that “didn’t or won’t go into effect as finalized.” The federal regulations website may still display the stayed text.

Only 89 Harris County residents chose a catastrophic plan for 2026. Our guide to catastrophic health plans in Houston walks through the exemption categories.

Three Houston households, worked through

These examples use published parameters only: the 2026 poverty guidelines, the 2027 limits, the 2027 applicable percentage table in Rev. Proc. 2026-26, and the 2026 federal brackets from the IRS inflation adjustments, the latest published. Premiums, which vary by insurer, ZIP code and age, are left out. Every tax figure is illustrative, and because Texas has no personal income tax, every saving is federal.

Example 1: a single 34-year-old contractor in the Heights

He works for himself and expects household income of about $58,000 for 2027 — roughly 363% of the poverty line for one. That is above the 250% ceiling for cost-sharing reductions and below the 400% ceiling for the premium tax credit. At 34, a catastrophic plan is off the table without an exemption.

The HSA side. A full 2027 contribution is $4,500. After the $16,100 standard deduction his taxable income is about $41,900, inside the 12% bracket, so the deduction offsets about $540 of federal income tax.

The credit side. The deduction brings household income to $53,500, still between 300% and 400% of the poverty line, where Rev. Proc. 2026-26 fixes the applicable percentage at 10.22%. His expected contribution toward the benchmark silver premium falls by 10.22% of $4,500, about $460 a year, so his credit could rise by that much — unless it is already capped at the full cost of his bronze plan.

The read. With no cost-sharing reductions to give up, bronze with an HSA deserves a serious look: about $1,000 a year in combined federal help in this illustration, against a $12,000 worst case in a bad year. Our guide to health insurance for self-employed Houstonians covers the other wrinkles.

Example 2: a family of four in Pasadena

Two parents, two children, household income of about $62,000 — roughly 188% of the poverty line for four. That puts them in the band where a silver plan comes with the 87% actuarial value variant and a 2027 family out-of-pocket limit of $8,000.

The HSA side. A full family contribution is $9,000, about 14.5% of their income. Filing jointly, their taxable income after the $32,200 standard deduction is about $29,800. A $9,000 deduction pulls $5,000 out of the 12% bracket and $4,000 out of the 10% bracket, offsetting up to about $1,000 of federal income tax — less if child tax credits already shrink their bill.

The coverage side. On bronze, the family’s out-of-pocket exposure can reach $24,000 in 2027. On the silver variant, it tops out at $8,000: a $16,000 difference in a bad year, against a tax benefit of about $1,000.

The read. For this family, silver with cost-sharing reductions usually deserves the first look. Bronze with an HSA can still fit a healthy family with savings to fund the account.

Example 3: a 58-year-old early retiree in Kingwood

She left her job at 57 and lives on part-time consulting and retirement account withdrawals, with household income of about $56,000 — roughly 351% of the poverty line for one. No cost-sharing reductions, but she qualifies for a premium tax credit. Medicare is seven years away.

The HSA side. At 58 she can contribute $4,500 plus the $1,000 catch-up, or $5,500 for 2027. Her taxable income after the standard deduction is about $39,900, in the 12% bracket, so the deduction offsets about $660 of federal income tax.

The credit side. Her household income drops to $50,500, about 316% of the poverty line and still in the flat 10.22% band. Her expected contribution falls by about $562, which could raise her credit by the same amount if it is not already capped at her bronze premium.

The read. Bronze with an HSA can do double duty for a pre-Medicare retiree. Publication 969 lists “Medicare and other health care coverage if you were 65 or older” among premiums an HSA can pay, and after 65 the 20% additional tax on non-medical withdrawals no longer applies. She will need to stop contributing six months before applying for Social Security or Medicare. Our guide to bridging to Medicare after early retirement covers the rest.

HouseholdIncome and poverty-line %Cost-sharing reductions?2027 HSA limitIllustrative federal helpBronze worst case
Single contractor, 34$58,000 · about 363%No$4,500About $540 tax + about $460 credit$12,000
Family of four$62,000 · about 188%Yes: $8,000 family limit on silver$9,000Up to about $1,000 tax$24,000
Early retiree, 58$56,000 · about 351%No$5,500 with catch-upAbout $660 tax + about $562 credit$12,000

What it means for Harris County

Harris County is the largest Marketplace market in Texas, and the new rule reaches a big share of it. The CMS 2026 Open Enrollment county-level public use file shows 731,300 Harris County plan selections for 2026. Of those, 681,933 (93.2%) received an advance premium tax credit and 225,823 (30.9%) received cost-sharing reductions.

Harris County, 2026 Open EnrollmentSelectionsShare
All Marketplace plan selections731,300100%
Gold275,01837.6%
Silver238,98532.7%
Bronze (now HSA-compatible)217,20829.7%
Catastrophic (now HSA-compatible)89Under 0.1%
Received an advance premium tax credit681,93393.2%
Received cost-sharing reductions225,82330.9%

Bronze is not a niche choice here: 217,208 people picked it, and many may not know they can now open an HSA. From north Houston to south Houston, the same federal rules apply.

Your Open Enrollment checklist

Open Enrollment for 2027 runs November 1, 2026 through January 15, 2027. The federal regulations website still shows a shorter window, but CMS confirmed in a July 27, 2026 statement that it “has not altered the dates” and that enrollment “will begin on November 1, 2026 and end on January 15, 2027.”

DateWhat happensWhy it matters for an HSA
Now through December 2026Current bronze enrollees can open an HSAExpenses before the account is established are not qualified medical expenses
November 1, 20262027 Open Enrollment beginsCompare bronze, silver and any HSA-designed plans side by side
December 1, 2026Last-month rule date for 2026Eligible on this date means eligible for all of 2026, subject to the testing period
December 15, 2026Last day to choose a plan starting January 1Keeps January 2027 an HSA-eligible month
January 1, 20272027 HSA limits take effect$4,500 self-only, $9,000 family, $1,000 catch-up at 55
January 15, 2027Open Enrollment ends; coverage starts February 1January would not be an eligible month
Due date of your 2026 federal returnLast day for 2026 HSA contributionsPublication 969 gave April 15, 2026 for 2025 contributions

Before you choose a plan

  1. Check who in your household is eligible. Medicare, a dependent claim, or a spouse’s general-purpose FSA can rule someone out.
  2. Estimate 2027 household income honestly. With no repayment cap, an optimistic guess can cost you at tax time.
  3. Find your cost-sharing band. At or under 250% of the poverty line — $39,900 for one, $54,100 for two, $68,300 for three, $82,500 for four — price the silver variants first.
  4. Compare worst cases, not just premiums. Add a year of premiums to each plan’s out-of-pocket maximum.
  5. Confirm your doctors, hospitals and prescriptions are covered by the exact plan.
  6. Enroll by December 15 if you want January to count as an HSA month.

Opening and funding the account

  1. Choose a trustee. HSAs are held by banks, insurance companies and other IRS-approved trustees; the account does not have to come from your health insurer.
  2. Decide how to contribute. Contributions through an employer’s cafeteria plan are excluded from income and generally not subject to employment taxes — 7.65% Social Security and Medicare withholding for most employees, per the IRS. If you buy your own coverage, you will usually contribute directly and claim the deduction on Form 8889.
  3. Count every contribution. Employer deposits reduce your limit. If both spouses are 55 or older, each needs their own HSA for their own catch-up.
  4. Keep your records. Save receipts for every withdrawal. Money spent on non-medical items before 65 is taxed plus a 20% additional tax.
  5. Loop in a tax professional for self-employment income, the 400% line or a mid-year start.
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The one question to bring to your plan review Not “is this plan HSA-eligible?” but “in a bad year, which plan leaves my household better off once premiums, the out-of-pocket maximum, the tax credit and the HSA deduction are all counted?” That is the comparison we run with clients every Open Enrollment.
Open Enrollment opens November 1

Find out whether bronze plus an HSA fits your household

Wise Insurance Agency is an independent, Texas-licensed agency serving Houston and Harris County. Bring your expected 2027 income, household size, doctors and prescriptions. We will compare silver cost-sharing options against bronze plans, show the out-of-pocket exposure on each, and flag where a tax professional should weigh in. No charge for the conversation.

Talk to a licensed Houston agent 832-400-6538

Prefer email? Reach us at sara@wisehealthins.com, or start with our health insurance page.

Frequently asked questions

I bought a bronze plan for 2026. Can I still open an HSA for this year?
Yes, if you are otherwise eligible. For months beginning after December 31, 2025, a bronze plan available as individual coverage through an Exchange counts as a high-deductible health plan, so you may have been eligible since January. Contributions for 2026 can generally be made until the due date of your 2026 federal return. But IRS Publication 969 says expenses incurred before you establish the HSA are not qualified medical expenses, so open the account soon.
Does my bronze or catastrophic plan have to come from the Marketplace?
Not necessarily. IRS Notice 2026-5, Q&A-6, says a bronze or catastrophic plan bought off-Exchange on the individual market is treated as an HDHP if the same plan is available through an Exchange, and Q&A-7 adds relief if you have no reason to believe it is unavailable on an Exchange. Bronze coverage through a small employer’s SHOP program generally does not qualify unless it meets the standard HDHP tests.
How much can I contribute to an HSA for 2027?
IRS Rev. Proc. 2026-24 sets the 2027 limits at $4,500 for self-only coverage and $9,000 for family coverage, up from $4,400 and $8,750 for 2026. If you are 55 or older by the end of the year, you can add $1,000; if both spouses are, each makes that extra contribution to their own HSA. Employer contributions count against the same limit.
Can I get a premium tax credit and contribute to an HSA at the same time?
With a bronze plan, yes. The premium tax credit can apply to bronze coverage, and the new HSA rule covers bronze plans available through an Exchange. Catastrophic plans are different: 26 U.S.C. 36B(c)(3)(A) excludes them from the plans that qualify for the credit. An HSA deduction also lowers adjusted gross income, the starting point for the household income the credit is based on.
Is a silver plan with cost-sharing reductions HSA-eligible?
Not under the new rule, which names only bronze and catastrophic plans. A silver plan, including a cost-sharing reduction variant, counts only if it meets the standard HDHP definition, which for 2027 means a deductible of at least $1,750 for self-only coverage and out-of-pocket costs no higher than $8,700. Because cost-sharing reductions come only with silver plans, choosing bronze to get an HSA means giving them up.
Can I keep a direct primary care membership and still contribute to an HSA?
Yes, for months after December 2025, if the arrangement qualifies. It must provide primary care from primary care practitioners for a fixed periodic fee only, and total fees cannot exceed $150 a month for one person or $300 for an arrangement covering more than one, the same for 2026 and 2027. Procedures requiring general anesthesia, prescription drugs other than vaccines, and lab work not typical of an ambulatory primary care setting are excluded.
Can more people buy a catastrophic plan in Texas for 2027?
Not as things stand. The 2027 rule that would have widened catastrophic eligibility, along with related guidance issued September 4, 2025, was stayed on July 16, 2026 in City of Columbus v. Kennedy, No. 1:26-cv-02215, according to a CMS statement dated July 31, 2026. Eligibility remains limited to people under 30 and people with an affordability or hardship exemption, even though the federal regulations website may still display the stayed text.
I am 58 and plan to move to Medicare at 65. When should I stop contributing?
Your HSA contribution limit drops to zero starting with the first month you are enrolled in Medicare, including retroactive coverage, per IRS Publication 969. Medicare.gov advises that you and your employer stop contributing six months before you retire or apply for Social Security benefits. Until then, a bronze plan can keep you eligible, with the $1,000 catch-up available from 55.

Sources

  1. Internal Revenue Service, “Notice 2026-5: Expanded Availability of Health Savings Accounts under the One, Big, Beautiful Bill Act,” Sections II.B and III (Q&A-1 through Q&A-20). https://www.irs.gov/pub/irs-drop/n-26-05.pdf
  2. Internal Revenue Service, “Treasury, IRS provide guidance on new tax benefits for health savings account participants under the One, Big, Beautiful Bill,” IR-2025-119, December 9, 2025. https://www.irs.gov/newsroom/treasury-irs-provide-guidance-on-new-tax-benefits-for-health-savings-account-participants-under-the-one-big-beautiful-bill
  3. Internal Revenue Service, “Rev. Proc. 2026-24,” 2027 HSA contribution limits, HDHP definitions and direct primary care fee limits. https://www.irs.gov/pub/irs-drop/rp-26-24.pdf
  4. Internal Revenue Service, “Rev. Proc. 2025-19,” 2026 HSA contribution limits and HDHP definitions. https://www.irs.gov/pub/irs-drop/rp-25-19.pdf
  5. Internal Revenue Service, “Rev. Proc. 2026-26,” Section 3.01, Applicable Percentage Table for 2027. https://www.irs.gov/pub/irs-drop/rp-26-26.pdf
  6. Internal Revenue Service, “IRS releases tax inflation adjustments for tax year 2026, including amendments from the One, Big, Beautiful Bill” (tax rate schedules and standard deduction). https://www.irs.gov/newsroom/irs-releases-tax-inflation-adjustments-for-tax-year-2026-including-amendments-from-the-one-big-beautiful-bill
  7. Internal Revenue Service, “Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans.” https://www.irs.gov/publications/p969
  8. Internal Revenue Service, “Updates to Questions and Answers about the Premium Tax Credit,” Fact Sheet FS-2025-10, December 2025, Q31. https://www.irs.gov/pub/taxpros/fs-2025-10.pdf
  9. Internal Revenue Service, “Topic no. 751, Social Security and Medicare withholding rates.” https://www.irs.gov/taxtopics/tc751
  10. United States Code, 26 U.S.C. § 223 (health savings accounts), including subsections (c)(1)(E), (c)(2)(E) and (c)(2)(H) as amended by Pub. L. 119-21, sections 71306–71308. https://www.law.cornell.edu/uscode/text/26/223
  11. United States Code, 26 U.S.C. § 36B (premium tax credit), subsections (b)(2), (c)(3)(A) and (d)(2). https://www.law.cornell.edu/uscode/text/26/36B
  12. Centers for Medicare & Medicaid Services, “Premium Adjustment Percentage, Maximum Annual Limitation on Cost Sharing, Reduced Maximum Annual Limitation on Cost Sharing, and Required Contribution Percentage for the 2027 Benefit Year,” January 29, 2026. https://www.cms.gov/files/document/2027-papi-parameters-guidance-2026-01-29.pdf
  13. Centers for Medicare & Medicaid Services, “Statement Regarding the City of Columbus v. Kennedy, No. 1:26-cv-02215,” July 31, 2026. https://www.cms.gov/files/document/statement-re-city-columbus-073126.pdf
  14. Centers for Medicare & Medicaid Services, “Updated Statement regarding the Failure to File and Reconcile requirement for Plan Years 2026-2027,” July 27, 2026. https://www.cms.gov/files/document/ftr-requirement-py26-27-statement.pdf
  15. Centers for Medicare & Medicaid Services, “2026 Marketplace Open Enrollment Period Public Use Files,” County-Level Public Use File, Harris County, Texas (FIPS 48201). https://www.cms.gov/data-research/statistics-trends-reports/marketplace-products/2026-marketplace-open-enrollment-period-public-use-files
  16. U.S. Department of Health and Human Services, Office of the Assistant Secretary for Planning and Evaluation, “HHS Poverty Guidelines for 2026.” https://aspe.hhs.gov/topics/poverty-economic-mobility/poverty-guidelines
  17. HealthCare.gov, “Catastrophic health plans.” https://www.healthcare.gov/choose-a-plan/catastrophic-health-plans/
  18. HealthCare.gov, “Reporting deductions on your Marketplace application.” https://www.healthcare.gov/reporting-deductions/
  19. HealthCare.gov, “Dates and deadlines for 2027 health insurance.” https://www.healthcare.gov/quick-guide/dates-and-deadlines/
  20. Medicare.gov, “Working past 65” (HSA contributions before applying for benefits). https://www.medicare.gov/basics/get-started-with-medicare/medicare-basics/working-past-65

For general educational purposes only; this is not tax or legal advice. It reflects federal statutes, IRS and CMS guidance, and data published as of September 2026. Several Marketplace provisions mentioned here are the subject of pending federal litigation, and their status can change. Tax results depend on your full return, so consult a tax professional about your situation. Wise Insurance Agency is a licensed insurance agency in the State of Texas and is not affiliated with or endorsed by any federal or state agency. Final eligibility, plan costs and credits are determined by the Marketplace, the issuer and the IRS.