Good God. Trump's Council of Economic Advisors are either clueless or sycophants.

Thu, 02/12/2026 - 6:20pm

Via the HHS Dept. website this morning:

WASHINGTON — The U.S. Department of Health and Human Services (HHS) announced today it is implementing important measures to expand access to more affordable catastrophic health coverage through HHS’ new hardship exemption guidance. This guidance streamlines access to more affordable catastrophic coverage for consumers who are ineligible for advance payments of the premium tax credit (APTC) or cost-sharing reductions (CSRs).

Through these efforts, more Americans will be able to qualify for catastrophic health coverage based on need, beginning November 1st with the start of open enrollment.

Let's stop a moment and look at what Catastrophic Plans actually are.

There are five main categories of ACA-compliant health insurance policies for the individual market: The four "Metal Tiers" of Bronze, Silver, Gold, Platinum which have to cover an average of roughly 60%, 70%, 80% or 90% of the aggregate enrollees medical claims...plus a fifth category at the low end (below Bronze) called Catastrophic plans.

I'll let my colleague Louise Norris explain:

Catastrophic plans are only available to certain applicants, have deductibles equal to the maximum annual out-of-pocket limit, and enrollees must pay at least part of the cost of up to three primary care visits before the deductible is met...In addition, an enrollee in a catastrophic plan is not eligible to have premium subsidies paid on their behalf.

And for the purposes of the ACA's risk adjustment program, catastrophic plans are in a separate risk pool from the metal-level plans.

...Their enrollees are mostly fairly affluent – since subsidies cannot be used with Catastrophic plans, the enrollees tend to be those who earn too much to qualify for subsidies – and under the age of 30, and the plans don't have to share risk with metal-level plans that tend to have a less healthy pool of enrollees).

...Catastrophic plans cover all of the essential benefits defined by the ACA, but with very high deductibles, equal to the annual limit on out-of-pocket costs under the ACA. For 2025, this is $9,200 for a single individual, increasing to $10,600 in 2026.

They must still limit members’ out-of-pocket costs for in-network services to no more than the annual out-of-pocket maximum that applies to all plans. (This cap is $9,200 for an individual in 2025, and $10,600 in 2026.).

...Like all ACA-compliant plans, catastrophic plans cover certain preventive care with no cost-sharing.

...An enrollee in a catastrophic plan is not eligible for premium subsidies. (and cost-sharing subsidies are also not available for Catastrophic plans.

Until now there've been very few Catastrophic Plan enrollees...just 54,000 or so this year out of over 24 million nationally...

...OK, back to this morning's HHS announcement: What's changing going forward?

Under new HHS guidance, consumers may qualify for a hardship exemption to purchase a catastrophic plan on or off the Exchange if they are determined or expect to be ineligible for APTC or CSRs based on their projected annual household income....With a hardship exemption, eligible consumers can enroll in a catastrophic plan through HealthCare.gov.

If I'm understanding this correctly, they're vastly expanding the "hardship exemption" to enrollees of any age who earn more than 250% of the Federal Poverty Level (FPL), since that's the income threshold limit for Cost Sharing Reduction (CSR) eligibility.

OK, the point is that Trump/RFK Jr. basically opened the floodgates on Catastrophic plan eligibility to millions more people...even though, as I went on to explain in that post, very few would actually benefit much from it since they offer fewer benefits than even the lowest-end Bronze plan while only costing slightly less (in fact, they actually cost more for some people).

As an example of this, consider the 63-yr old couple living in Atlanta, Georgia earning $85,000/yr who I used in this October 2025 post:

Unfortunately, in this case, the least-expensive plan (a Bronze HMO which more than doubles the deductible from $9,000 to $21,200) would still cost $2,386/month...or over 1/3 of their income in premiums alone.

How about the Trump Regime's new opening of the floodgates on Catastrophic plan eligibility?

...They'll both be 64 next year, and assuming the Age Band multiplier for Catastrophic plans is the same as it is for other individual market plans in Georgia, you'd have to multiply those prices by 2.68, which would put the cost of a Catastrophic plan for this couple at $2,286 or $2,565/month...basically the same as a Bronze plan anyway.

I mention all of this because I'm finally digging into the 2027 Notice of Benefit & Payment Parameters (NBPP), and wanted to get Katie Keith's take on it (she's the Director of Health Policy & the Law Initiative at the O'Neill Institute for National & Global Health Law at Georgetown University Law Center, which is a hell of a mouthful but the point is she knows this stuff inside and out).

So, I was reading the introduction to Keith's own look at the 2027 NBPP, and this passage about Catastrophic plans caught my eye:

The Trump administration and Republicans in Congress have embraced catastrophic plans. In September 2025, HHS issued new guidance to expand hardship exemptions for consumers in the states where the FFE processes these exemptions. The White House Council of Economic Advisers believes this change will increase enrollment in catastrophic plans from about 20,000 people nationwide for 2025 to 3 million people nationwide for 2026. This guidance followed changes in the OBBBA to make all catastrophic and bronze plans eligible for health savings account (HSA) contributions by treating them as high-deductible health plans.

Wait, what??

Well, for starters, the 20,000 figure comes from the actual text of the rule itself (page 252)...

"In 2016, nearly 100,000 people enrolled in catastrophic plans, but only about 20,000 people enrolled in catastrophic plans in 2025."

...which is already wrong, since 2025 Catastrophic plan enrollment was actually just over 54,000. So, y'know, the Trump regime isn't off to a great start here.

More to the point, however, it's the 3 MILLION projection by the White House CEA which made my jaw drop. Where the hell did that come from?

Well, here's the white paper she's referring to:

Expansion of HSA Eligibility Under OBBB Act to Improve Marketplace Coverage, Affordability, and Access

Prior to the One Big Beautiful Bill Act (OBBB), only some High-Deductible Health Plans (HDHPs) were considered Health Savings Account (HSA) eligible. Catastrophic health plans were not defined as HDHPs and were therefore, not HSA eligible. In 2025 only 2% of HealthCare.gov Marketplace enrollees selected HSA‑eligible plans—a sharp decline from 7% in 2020 (Centers for Medicare & Medicaid Services 2025a). Effective January 1, 2026, the OBBB reclassifies Bronze and Catastrophic ACA Marketplace plans as qualifying HDHPs, enabling millions more enrollees to open and contribute to HSAs without having to change insurance plans (Andrews, 2025). Approximately 30% of Marketplace enrollees selected Bronze plans during the 2025 OEP—an estimated 7.27 million people (Centers for Medicare & Medicaid Services 2025b). Catastrophic enrollment, while much smaller (54,000) because of highly restrictive enrollment criteria, adds to this total, making an additional 7.3 million Americans eligible for HSAs at current enrollment levels.

On September 3, 2025, the Centers for Medicare and Medicaid Services (CMS) announced changes to catastrophic enrollment processes that will further expand the number of Americans eligible for HSAs. Previously, catastrophic plans were restricted to those under 30 years old or individuals who qualify for a hardship exemption. CMS has expanded eligibility for those over 30 to qualify for catastrophic plans through the Obamacare law’s hardship enrollment pathway. These expansions in catastrophic eligibility will likely increase enrollment by several million more. We estimate the additional enrollment of 3 million in catastrophic plans coupled with the expansion of HSA eligibility for bronze and catastrophic plans, will increase the number of Americans eligible for an HSA to 10 million.

Wow. That's...quite a projection. But it gets even more curious: If you scroll down to page 6-7, they have a table which breaks out total 2025 ACA exchange plan selections (further broken out by total, Bronze and Catastrophic)...and then add 3 additional projection columns for each state: Newly HSA-eligible; Additional Estimated Catastrophic Enrollment and Total Estimated Newly HSA-Eligible.

Now, all of the 2025 columns are accurate; they match up with the data in the 2025 OEP Marketplace Public Use File. And I'm not even going to get into the "Newly HSA-Eligible" column; that could very well be accurate.

But the "Additional Estimated Catastrophic Enrollment" column, which does indeed add up to almost exactly 3.0 million people, is quite the head-scratcher. Even if you just think they were being wildly optimistic, they somehow thought that nearly 560,000 people would enroll in Catastrophic plans this year in states which don't offer Catastrophic plans.

That's right: Alaska, Louisiana, Minnesota, Mississippi, Nebraska, New Mexico, North Carolina, Ohio, Oregon, Rhode Island, South Carolina, Tennessee, Utah and Wyoming don't offer any Catastrophic plans in 2026.

Is it possible that the WH Council of Economic Advisors simply didn't realize that some states don't offer Catastrophic plans? I mean, that would be pretty embarrassing, but it might explain it...except that ten states didn't offer them LAST year, which they DID recognize (note the dashes in the 2025 column for AK, AR, IN, LA, MS, NM, OR, RI, UT & WY).

But wait, there's more! The expansion of Catastrophic plan eligibility also wouldn't apply to California, Connecticut, Maryland or the District of Columbia either:

This guidance applies to consumers in FFE states and in States served by State-based Exchanges (SBEs) that choose to have exemptions processed through the FFE, which currently include all SBEs except California, Connecticut, Maryland, and the District of Columbia.

That's another ~287,000 people Trump's Economic Advisors projected to enroll in Catastrophic plans in 2026 who aren't eligible to do so even if their already absurd expectations were otherwise being met. Combined, that's around 847,000 of the 3.0 million for whom enrolling in a Catastrophic plan literally couldn't happen anyway.

OK, but what about the other 33 states which a) do offer Catastrophic plans this year and b) would be subject to the eligibility expansion laid out in September?

Well, the official 2026 OEP Public Use File likely won't be available until late April or early May, but New Jersey and Washington have published enrollment breakouts by type of policy, and...well...

New Jersey: 1,279 (WH CEA projection: 60,150)
Washington: ~2,900* (WH CEA projection: 38,263)

*("Catastrophic customers are excluded because they account for fewer than 1% of the QHP population")

Across all 20 states, that's a grand total of less than 4,179 Catastrophic enrollees vs. the Trump regime's projection of ~945,000.

Par for the course for an administration which claims that they're going to "reduce drug prices by 1,500%" I suppose...

So what actually happened here? Well, considering that the grand total of their seemingly random "additional Catastrophic enrollee" numbers somehow add up to exactly 3.0 million, I'm going to assume that someone just decided that "3 million!" sounded like a solid, round number and that they worked it backwards from there. That's speculation, of course.

For what it's worth, the "Council" of Economic Advisors appears to actually only consist of two people: