New guidance from the U.S. Department of Health and Human Services (HHS) will expand consumer access to affordable catastrophic healthcare policies. NAIFA has long advocated for access to affordable catastrophic health plan options.
Under the new policy, consumers who are not eligible for advance payments of premium tax credits or cost-sharing reductions on the Health Insurance Marketplace are eligible for hardship exemptions allowing them to purchase catastrophic plans beginning November 1.
Catastrophic plans offer consumers lower premiums and generally cover high medical costs that may arise from serious illnesses and injuries. They also cover preventative services required under the Affordable Care Act and up to three pre-deductible visits with primary care physicians. The exemption will apply to consumers purchasing plans either on or off the Exchange.
Beginning November 1, 2025, consumers can apply for the hardship exemption in two ways:
HHS is also simplifying the process by streamlining the review of paper applications to reduce the administrative burden on consumers. This change will make it easier for individuals experiencing hardship and seeking a catastrophic plan to access the full range of catastrophic coverage options available to them.
HHS’ hardship exemption guidance for catastrophic coverage can be viewed on CMS.gov at: https://www.cms.gov/marketplace/resources/regulations-guidance#Health-Insurance-Marketplaces
A fact sheet on HHS’ hardship exemption guidance for catastrophic coverage is available at: https://www.cms.gov/newsroom/fact-sheets/expanding-access-health-insurance-consumers-gain-access-catastrophic-health-insurance-plans-2026