IMPORTANT: New Guidance on Hardship Exemptions and Catastrophic Coverage Options

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New Guidance on Hardship Exemptions and Catastrophic Coverage Options 

The Centers for Medicare & Medicaid Services (CMS) issued new guidance on Thursday, September 4, 2025 that describes circumstances that fall under the Federally-facilitated Exchange’s (FFE’s) hardship exemption policy for Plan Year 2026 and future years to help address the significant rise in health insurance premiums by expanding access to more affordable catastrophic coverage options.

 

Specifically, this guidance describes circumstances that will support a hardship exemption for those who are ineligible for advance payments of the premium tax credit (APTC) or cost-sharing reductions (CSRs) due to their income, which will allow them to enroll in catastrophic coverage.

 

In addition, this guidance describes how CMS will begin streamlining the process for accessing this hardship exemption through HealthCare.gov and through the paper exemption application to make it easier to enroll in catastrophic coverage for additional populations in the future.

 

You can access the guidance here:

https://www.cms.gov/files/document/guidance-hardship-exemptions.pdf

 

For additional information on the hardship exemptions, view the CMS press release and fact sheet:

 

 

Have questions? For additional assistance, contact the Agent/Broker Email Help Desk via email at FFMProducer-AssisterHelpDesk@cms.hhs.gov