Policy Changes to Boost Catastrophic Coverage as Premium Tax Credits Expire

HHS made change considering the expected increase in individual market premiums and the expiration of the enhanced premium tax credits
Sept. 4, 2025
2 min read

Key Highlights

  • HHS's new guidance simplifies access to catastrophic health coverage for consumers ineligible for premium tax credits or cost-sharing reductions.
  • Eligibility for expanded catastrophic plans will be based on estimated annual household income, starting November 1st during open enrollment.
  • Catastrophic plans typically feature lower premiums and cover essential services like three primary care visits before deductibles apply.
  • The policy aims to mitigate financial hardship caused by rising premiums, especially for those who cannot qualify for subsidies.
  • This initiative responds to the potential economic impact of expiring premium tax credits and rising healthcare costs nationwide.

In a press release on September 4, the U.S. Department of Health and Human Services (HHS) announced it is implementing measures to increase access to more affordable catastrophic health coverage through HHS’s new hardship exemption guidance. According to the news brief, the guidance simplifies access to cheaper catastrophic coverage for consumers who are ineligible for advance payments of the premium tax credit (APTC) or cost-sharing reductions (CSRs).

The Centers for Medicare & Medicaid Services (CMS) made this change in response to the expected increase in individual market premiums and the expiration of the enhanced premium tax credits at the end of the year, the American Hospital Association (AHA) noted.

Previously, Healthcare Innovation reported on a study from the Commonwealth Fund and the George Washington University Milken Institute School of Public Health, which found that if Congress allowed enhanced premium tax credits to expire at the end of 2025, communities across the country would face significant economic impacts. “The enhanced premium tax credits, which began in 2021 and were extended through 2025 by the Inflation Reduction Act, have made Affordable Care Act (ACA) health insurance marketplace plans more affordable for millions of Americans,” contributing senior editor David Raths wrote.

More Americans will qualify for catastrophic health coverage based on need starting November 1st, when open enrollment begins. Eligibility will be determined by estimated annual household income. “Catastrophic plans generally have lower monthly premiums, are designed to protect consumers from very high medical costs in the event of serious illness or injury, and are required to cover three primary care visits pre-deductible,” HHS explained.

CMS released a fact sheet on HHS’s hardship exemption guidance for catastrophic coverage, noting that significant rate increases can cause hardship in obtaining coverage under a QHP, especially for consumers whose income disqualifies them from receiving APTC or CSRs to reduce their out-of-pocket costs.

About the Author

Pietje Kobus

Pietje Kobus

Pietje Kobus has an international background and experience in content management and editing. She studied journalism in the Netherlands and Communications and Creative Nonfiction in the U.S. Pietje joined Healthcare Innovation in January 2024.

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