
By JoAnn Volk, Sabrina Corlette, and Justin Giovannelli
On September 4, 2025, the U.S. Department of Health and Human Services (HHS) released guidance expanding eligibility for catastrophic health plans. These plans were created by the Affordable Care Act (ACA) and are currently available to a narrowly defined universe of individuals based on age and specific circumstances, and are designed to provide basic protection from catastrophic health costs. Noting a need to help people “address the significant rise in health insurance premiums,” HHS’ guidance significantly expands the universe of individuals eligible for these plans, with potential implications for consumers’ access to premium tax credits, states’ individual insurance markets, and premiums for both catastrophic and individual market “metal level” (bronze, silver, gold and platinum) plans.
In their latest Expert Perspective for the Robert Wood Johnson Foundation’s State Health & Value Strategies program, CHIR’s JoAnn Volk, Sabrina Corlette, and Justin Giovannelli review HHS’ new guidance and assess the implications for consumers, insurance markets, and state insurance regulators. You can read the full post here.