Health Savings Accounts and ACA Marketplace Coverage — Frequently Asked Questions

This article covers how Health Savings Accounts work with ACA Marketplace coverage, which Marketplace plans are HSA-eligible, and how HSA contributions affect a consumer's eligibility for Marketplace financial assistance.

A Health Savings Account (HSA) is a savings account that helps individuals pay for health care costs on a tax-advantaged basis. Contributions to an HSA are tax-free, withdrawals used for qualified medical expenses — such as deductibles, copayments, and coinsurance — are tax-free, and any earnings in the account grow tax-free.

Withdrawals used for non-medical expenses are subject to ordinary income tax plus an additional 20% penalty tax. The 20% penalty is waived if the account holder is 65 or older, becomes disabled, or dies — in those cases, only ordinary income tax applies.

Individuals may contribute to an HSA when they are enrolled in an HSA-eligible health plan and have no other disqualifying coverage. Disqualifying coverage includes a general-purpose flexible spending account, Medicare, or certain employer-sponsored benefits.

Anyone may contribute to an eligible individual's HSA, including the account holder, household members, friends, and employers. There is no minimum contribution. The table below shows the maximum HSA contribution limits for 2025 and 2026.

Individuals age 55 or older may make an additional $1,000 catch-up contribution per year. If both spouses are 55 or older, each may make a catch-up contribution to their own HSA. A spouse may not contribute catch-up funds to the other spouse's HSA.

Individuals should retain receipts for all medical expenses paid using HSA withdrawals. It is the account holder's responsibility to maintain records of medical costs and expenses in the event of an IRS audit.

Starting in 2026, all bronze and catastrophic plans available as individual coverage through the Marketplace — including plans on Federally-facilitated Exchanges (FFEs), State-based Exchanges on the Federal platform (SBE-FPs), and State-based Exchanges (SBEs) — automatically qualify as high-deductible health plans (HDHPs) and are HSA-eligible.

Identical bronze and catastrophic plans available off-Exchange in the individual market are also HSA-eligible.

Bronze and catastrophic plans offered exclusively off-Exchange are not automatically HSA-eligible. Those plans must still meet the traditional IRS requirements for an HDHP to be paired with an HSA.

Other metal-level plans — silver, gold, and platinum — may be HSA-eligible if they meet IRS requirements for an HDHP, but this is not automatic.

When previewing plans and prices on HealthCare.gov, agents and consumers can select the "Eligible for an HSA" filter to view all HSA-eligible plans available in their area.

Yes. HSA contributions are treated as an above-the-line deduction, which reduces a consumer's Modified Adjusted Gross Income (MAGI). MAGI is the income figure the Marketplace uses to determine eligibility for Advance Payments of the Premium Tax Credit (APTC) and cost-sharing reductions (CSRs).

The Marketplace application does not directly collect HSA contribution amounts, but consumers may factor expected HSA contributions into their estimated annual income when completing the application. For consumers whose estimated income is close to an APTC eligibility threshold, HSA contributions can make a meaningful difference — either qualifying the consumer for APTC they would not otherwise receive, or increasing their APTC amount.

Example: Samuel, age 32, lives in Miami, Florida and is applying for Plan Year 2026 coverage in a bronze plan. Samuel earns $64,000 per year, which is over 400% of the FPL, making him ineligible for APTC. If Samuel contributes $1,800 to an HSA during the year, his estimated MAGI is reduced to $62,200, which falls under 400% of the FPL. Based on the updated projected income, Samuel could qualify for approximately $116 per month in APTC, if otherwise eligible.

If a consumer contributes to their HSA through payroll deductions, those contributions are deducted from wages before taxes are calculated and are already reflected in the consumer's taxable income.

Note: Consumers enrolled in catastrophic plans are not eligible for APTC regardless of income.

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