Catastrophic Plans in 2026: A Hardship Option… That Still Leaves You on the Edge

As ACA premiums rise and enhanced subsidies expire after 2025, millions of Americans are bracing for higher costs in 2026. In response, the government expanded the hardship exemption, allowing more people to enroll in catastrophic Marketplace plans even if they’re over age 30.

It’s being positioned as relief, but consumers deserve to understand what these plans really do (and don’t) cover. Catastrophic plans offer lower monthly premiums, but come with extremely high deductibles, very limited pre-deductible care, and no subsidies.
They protect you from financial collapse—not from the real costs of staying healthy.

What’s Changing for 2026 — and Why It Matters

For years, catastrophic plans were mostly limited to people under 30 or those dealing with very specific hardships. But 2026 it is different.  If you don’t qualify for subsidies anymore, you may suddenly find yourself eligible for a catastrophic plan, even if you’re well over 30.

Here’s who gets pulled into this new category:

• People who aren’t eligible for subsidies at all
• People whose income is below 100% of the Federal Poverty Level
• Anyone whose income is above 400% of FPL
• And even people above 250% of FPL who don’t qualify for cost-sharing help

It’s meant to fill a gap, but it doesn’t fix the underlying issue of affordability.

What Catastrophic Plans Actually Look Like in 2026

Here are the official U.S. Department of Health and Human Services deductible amounts for 2026:

• Individual deductible: $10,650

• Family deductible: $21,300

These numbers matter because almost nothing is covered until you reach them, aside from preventive services and, in some cases, three primary care visits.
Everything else, diagnostics, imaging, labs, urgent care, specialist appointments, is paid entirely out of pocket until you cross those high thresholds.

Feature	What Sounds Good	The Reality
Lower monthly premiums	Easier to afford upfront	Nearly all healthcare spending is out-of-pocket
Essential health benefits included	ACA compliant	Benefits don’t apply until you meet the entire deductible
A few preventive services covered	Annual wellness, vaccines	Anything diagnostic comes out of your pocket
Emergency protection	Helps in a crisis	Only after you’ve spent $10k+ first

New for 2026: Catastrophic Plans Can Now Be HSA-Eligible

This update has caused confusion, so here’s the clear version:
Beginning in 2026, Marketplace catastrophic plans can qualify as HSA-eligible.

This is only possible because:
The Centers for Medicare & Medicaid Services,(CMS), now allows issuers to waive the three mandatory pre-deductible primary care visits
(which is what previously blocked HSA qualification).
Adding HSA eligibility does not make care cheaper it simply allows consumers to pay the high out-of-pocket expenses using tax-advantaged dollars.

A Smarter Alternative If You’re Already Paying Self-Pay Prices

Here’s the reality most people discover (often the hard way):

If you’re willing  or forced  to pay for routine care out of pocket with a catastrophic plan,
you can often get better protection and lower monthly costs through a healthcare membership or cost-share model.

Here’s why:

Catastrophic plans make you self-pay for almost everything anyway.

Sick visits, urgent care, imaging, labs, specialists, none of it counts until you hit the $10,650 or $21,300 deductible.
Most families will never hit that number, which means they’re essentially paying premiums for a plan they are still afraid to use.

Cost-share memberships flip the model.

Instead of:

• High premiums

• High deductibles

• Limited networks

You pay:

• Much lower monthly rates

• A predictable IUA (typically $1,000–$2,500) when high cost medical needs occur

• More freedom to choose who cares for you
• Preventive care is include din many of the options + more access to virtual health and other services

“If I’m going to self-pay anyway, I’d rather self-pay at fair prices with support and not be stuck with a $10,650 deductible.”

You get immediate value, not just a parachute.

Membership-based healthcare isn’t designed around a huge deductible.

It’s designed around:

• Transparent pricing

• Open networks

• Predictable out-of-pocket costs

• Help navigating care

• Real savings on diagnostics, labs, and imaging

Meaning you don’t have to wait for a crisis to get value , it’s built into how you access care every day.

Where Catastrophic Plans Will Not Be Available in 2026

These states have formally prohibited catastrophic plans for the 2026 plan year:

• California

• Connecticut

• Maryland

• District of Columbia

• New York

• Massachusetts

If you live in these states, catastrophic plans won’t appear on your exchange at all.

How to Apply for the Hardship Exemption

CMS, the federal agency that oversees HealthCare.gov and Marketplace rules, has streamlined the process for 2026.
Online (recommended)
Apply on HealthCare.gov → choose to check for financial assistance → the system automatically determines hardship exemption eligibility.

Mail-in option

Use the paper hardship exemption form and select:
“Hardship 14 – You experienced another hardship.”
Include a short explanation related to subsidy ineligibility.

The Hard Truth: This ‘Affordable’ Option Still Leaves Families Exposed

Catastrophic plans are designed for a worst-case emergency not for the 15–20 everyday healthcare needs families experience each year:

• sick visits

• mental health

• kids’ injuries

• women’s health

• diagnostics

• imaging

• labs

• chronic condition management

With catastrophic plans, all of these are full price until you’ve paid $10,650 or $21,300.
Paying $800–$1,200 a month in premiums hurt. Paying $12,000 out of pocket when your kid breaks an arm will hurt a lot more. This is why so many consumers are opting out entirely or looking for smarter, more predictable alternatives.

Consumers Deserve Better Options

If all you want is a financial parachute, catastrophic plans accomplish that.
But most families want:

• Affordable care before hitting a crisis

• Predictable pricing

• Open access to providers

• No huge deductibles

• Everyday care that doesn’t break the budget

There are emerging options that deliver these benefits without massive premiums or six-figure deductibles.

Need Help Understanding Your Choices for 2026?
If you’re unsure how the subsidy loss or hardship exemption affects you, reach out. We can compare your options, model your costs, and walk through smarter alternatives.