Eligible HealthCare.gov Enrollees Average 35 HSA-Eligible Plans, CMS Says

Two days before open enrollment opened, the Centers for Medicare & Medicaid Services put a number on the new HSA rules. In its Plan Year 2027 Marketplace Plans and Prices fact sheet, dated Oct. 30, CMS says eligible HealthCare.gov enrollees “will have access to 35 different health plans on average that are HSA-eligible.” It calls that “a more than 1,000% increase over the status quo prior to” what it calls the “Working Families Tax Cuts.”

The fact sheet never mentions direct primary care. The IRS guidance underneath it does, and it changes what a DPC member should look for while shopping between now and Jan. 15.

Where the 35 plans come from

The One Big Beautiful Bill Act amended the tax code so that bronze and catastrophic plans count as high deductible health plans.

IRS Notice 2026-5 spells it out in Q-4. Starting with months after Dec. 31, 2025, a bronze or catastrophic plan “will be treated as an HDHP” if it’s available as individual coverage through an Exchange. That holds even when the plan misses the usual minimum deductible or out-of-pocket rules.

Before the law, the notice says, many bronze plans failed those tests. Catastrophic plans never could pass, because the ACA requires them to cover three primary care visits before the deductible.

The fact sheet doesn’t say how much of its count is bronze and catastrophic plans that now carry the new label. It also doesn’t publish how it calculated the average, or the baseline behind the 1,000% figure. Treat both as the agency’s own numbers.

Two other details from the notice matter for shoppers. Under A-6, a bronze or catastrophic plan bought off-Exchange still qualifies if the same plan is sold on an Exchange. And catastrophic plans keep their age gate: the notice restates the ACA rule that enrollment is limited to people under 30, or to people who qualify for a hardship or affordability exemption.

Where a DPC membership fits

The second change in the law is the one a DPC practice cares about. A direct primary care service arrangement is no longer treated as a health plan that blocks HSA contributions, as long as the fees stay under a monthly limit.

For 2027, Revenue Procedure 2026-24 keeps that limit at $150 a month, or $300 when the arrangement covers more than one person. The same document sets the 2027 HSA contribution ceilings at $4,500 for self-only coverage and $9,000 for family coverage.

Put the two together and you get the combination the fact sheet doesn’t describe. An otherwise eligible person who pairs a bronze or catastrophic plan with a DPC membership at or under the limit can contribute to an HSA in 2027, up to those ceilings. They can also pay the membership fee from that HSA.

The limit is narrower than it looks. Notice 2026-5’s A-20 says there is “no specific limit on the amount of the fixed periodic fee” for paying it from an HSA. A fee above $150 is still reimbursable. What it costs the member is eligibility: they can’t make new HSA contributions in any month they’re enrolled.

For a practice charging $160 a month, that’s a real conversation with a member who just picked a bronze plan. The fee is still payable from the HSA, but the member can’t make new contributions while the membership runs.

The notice adds one more wrinkle in a footnote. It says bronze plans are treated as HDHPs “regardless of which services they cover before the deductible.” It also notes Treasury’s understanding that the ACA lets marketplace plans provide coverage through a direct primary care medical home plan. Maine already has a 2027 bronze plan that builds in a DPC network.

Q-4 covers plans on any Exchange set up under the ACA, which includes the states that run their own. The fact sheet describes HealthCare.gov.

What changes on Jan. 1

Open enrollment on HealthCare.gov opened Nov. 1 and runs through Jan. 15. A patient who picks a plan by Dec. 15 has coverage starting Jan. 1. Someone who enrolls between Dec. 16 and Jan. 15 starts Feb. 1. Either way, coverage starts only after the first premium is paid.

What changes is the arithmetic for the patient who buys coverage alone. If one of your members is weighing a bronze plan this week, the HSA answer turns on two facts: the plan has to be bronze or catastrophic, and your fee has to sit at or under $150 a month. With both in place, and no other coverage that disqualifies them, they can generally contribute up to $4,500 on self-only coverage next year. A fee over the line still gets paid from the account, but the account stops taking new money for as long as the membership runs.