This article covers how catastrophic health plans work within the ACA Marketplace, who is eligible to enroll, and the rules governing repayment of excess Advance Payments of the Premium Tax Credit (APTC) beginning in Plan Year 2026.
For a full overview of ACA metal levels, network types, and financial assistance options, see ACA Plan Types, Metal Levels, and Financial Assistance Guide.
Key Terms
Key Terms
Catastrophic health plan: A Marketplace plan with low monthly premiums and a very high deductible. Consumers cannot apply APTC to a catastrophic plan.
Advance Payments of the Premium Tax Credit (APTC): Federal financial assistance paid directly to a consumer's insurance carrier to reduce their monthly Marketplace premium. If actual income at tax time differs from projected income, the consumer may owe back some or all of the APTC received.
Excess APTC: The amount by which the APTC a consumer received exceeds the Premium Tax Credit they are allowed based on actual household income reported on their tax return.
Exemption Certificate Number (ECN): A number issued by the Marketplace to consumers approved for a hardship or affordability exemption. Consumers over age 30 who want to enroll in a catastrophic plan must include their ECN on their Marketplace application.
What are catastrophic health plans and who can enroll in one?
Catastrophic health plans are Marketplace plans with low monthly premiums and very high deductibles. They cover at least three primary care visits per year and recommended preventive services before the deductible is met.
Consumers cannot apply APTC to a catastrophic plan. To enroll, a consumer must either be under 30 years of age, or be 30 or older with an approved affordability or hardship exemption.
How does a consumer over 30 enroll in a catastrophic plan using a hardship or affordability exemption?
Consumers age 30 or older must complete the exemption application form and include their Exemption Certificate Number (ECN) with their Marketplace application. There must be a separate ECN for each person in the household who qualifies for an exemption.
Are there limits on how much excess APTC a consumer must repay?
Plan Year 2026 and later — no repayment cap:
Beginning in Plan Year 2026, there is no cap on the amount of excess APTC a consumer must repay. Per Section 71305 of Public Law 119-21, the consumer must repay the full excess APTC amount when filing taxes. There is no limit regardless of household income.
Agents and brokers should make clients aware of this rule when discussing APTC amounts, particularly for clients whose actual income may differ from their projected income at enrollment.
Important exception: IRS rules allow a consumer to qualify for the PTC — and therefore avoid owing back their APTC — when their household income falls below 100% of the FPL, provided they were enrolled with APTC based on a projected income of at least 100% FPL and did not intentionally misrepresent their household income.
Plan Years before 2026 — repayment caps applied:
Household Income as % of FPL | Repayment Cap (Single Filer) | Repayment Cap (All Other Filers) |
Less than 200% | $375 | $750 |
200% to less than 300% | $950 | $1,900 |
300% to less than 400% | $1,575 | $3,150 |
400% or above | No cap | No cap |
Additional Resources
For additional help please contact Producer Support, which is available by chat directly from your account, by phone at (866) 568-9649, or by email at [email protected].