Policy Changes Bring Renewed Focus on High-Deductible Health Plans

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The expiration of the Affordable Care Act’s enhanced premium tax credits, along with the passage of the budget reconciliation law, implementation of new Marketplace regulations, and other administrative changes, could bring significant changes to ACA Marketplace enrollment and affordability for the 2026 plan year and beyond. Anticipated increases in what enrollees pay for premiums and new standards for health savings accounts (HSAs) could lead some consumers to consider plan options with lower premiums in exchange for higher deductibles, such as catastrophic or bronze plans. This issue brief examines key features of bronze and catastrophic plans, recent policy changes, coverage and costs, and the complicated choices for consumers.

Affordable Care Act (ACA) qualified health plans (QHPs) are categorized into four “metal levels” based on the overall amount of cost sharing they require: bronze, silver, gold, and platinum, plus catastrophic plans, which are a separate tier of QHPs. Bronze and catastrophic plans offered through the Marketplaces must cover essential health benefits, limit the amount of annual cost sharing for covered benefits ($10,600 for an individual or $21,200 for a family in 2026), cover certain preventive services without cost sharing, and have other ACA-required consumer protections.

There are several notable differences between the characteristics of bronze and catastrophic plans (Table 1). Bronze plans usually have the lowest premiums of all metal levels, but the highest deductibles. Catastrophic plans often, but not always, have even lower premiums than bronze plans, but a higher level of cost sharing. In 2026, bronze plans have an average deductible of $7,476, while catastrophic plans have deductibles equal to the out-of-pocket maximum allowed under the ACA ($10,600 for an individual or $21,200 for a family in 2026).

Both bronze and catastrophic plans can be purchased on or off the Marketplaces, but premium tax credits are only available for metal level plans that are sold on the Marketplace, meaning they cannot be applied to any plans sold off the Marketplace, nor to catastrophic plans. (Cost-sharing reductions— which lower out-of-pocket costs for enrollees with income between 100% and 250% of the federal poverty level (FPL)—are only available for silver plans on the Marketplace.)

Actuarial value — the expected share of health care expenses a plan covers for a standard population — also differs between bronze and catastrophic plans. Bronze plans are currently required to have an actuarial value (AV) between 58% and 62%, though the AV for expanded bronze plans can be as high as 65%. (Regulations finalized in June 2025 would permit an AV as low as 56% for standard bronze plans, but a court ruling has temporarily blocked that provision (and others) from taking effect.) Catastrophic plans, on the other hand, are not required to meet minimum actuarial value targets, except that they must have a lower AV than bronze plans. However, due to the permitted range of bronze actuarial values, the “generosity” of these two types of plans can be similar.