Health systems are often described as being “on the brink” of consumerism, as though the challenge were still one of future readiness. Even OpenAI is banking on the consumerization of health, announcing ChatGPT Health earlier this month, which allows users to review medical test results and connect to electronic medical records and wearable devices.
Change in consumer behavior is being driven less by retail disruption than by the financial architecture of coverage itself. More consumers now encounter health care as a self-directed purchasing decision rather than a plan-mediated benefit, and that change has profound implications for how access should be designed.
High-deductible health plans paired with health savings accounts (HSAs) have become a defining feature of the commercial insurance market. Among higher-income and professionally employed populations, these plans are not viewed as a burden but as a tradeoff: lower premiums in exchange for greater control over how health care dollars are spent. Today, over 50% of private sector workers have access to HSA eligible plans already, and affordability challenges are making them more necessary.
Government regulation is making these plans more attractive and accessible, with multiple Senate proposals—though not yet law—that would use HSAs as the primary mechanism for federal support tied to the ACA marketplaces. Key provisions within the One Big Beautiful Bill Act expanded HSA eligibility to all bronze and catastrophic plans while making catastrophic plans more broadly accessible to the market. With affordability challenges reaching a threshold, buy-downs into these low cost, high out-of-pocket plans will accelerate, making them the new standard for Commercial / Employer Sponsored Insurance.
How HSAs shape patient expectations
For more than 80% of patients covered under these plans, no reimbursement is likely to be received from the insurance given the magnitude of the deductible. This means a growing share of patients will arrive at the point of care acutely aware that they will be paying out of pocket, often with funds they personally manage and expect to steward carefully. So, commercially covered patients will look much more like “Self-Pay” than the “Commercial Insurance” financial class.
HSAs reinforce this mindset. The dollars roll over year to year, follow individuals across jobs, and can be invested. They can be used for a wide range of qualified medical expenses, including digital and hybrid offerings. Unlike traditional benefit designs, HSAs encourage consumers to think about health care spending not episodically, but holistically. Each decision is weighed not just against immediate need, but against long-term value.
This is why consumers with HSAs behave differently when engaging with health systems. They are less interested in navigating care one visit at a time and more interested in understanding what an episode of care actually entails. They want to know what will happen, who will be involved, how long it will take, and what it is likely to cost overall.
Aligning access models with informed consumer expectations
Health systems coordinate care across settings, manage clinical risk, and understand how individual encounters connect into larger treatment plans. Yet those strengths are rarely translated into consumer-facing access models. Instead, care is often presented as a series of disconnected entry points, each optimized for scheduling or billing rather than comprehension.
At the same time, many consumers now begin their health journey outside the system entirely, using digital tools—including AI-enabled search and chat interfaces—to orient themselves, assess urgency, and develop a preliminary understanding of what care might involve. Surveys cited by Becker’s Hospital Review suggest that roughly four-in-ten consumers interact with AI-generated health information in some form. While many consumers will arrive with expectations already formed, most remain cautious and explicitly want professional confirmation.
This dynamic raises the stakes for access design. Consumers who are both financially exposed through high deductibles and cognitively primed through digital information are not looking to be funneled into generic scheduling workflows. They want to see that the system understands the problem they are trying to solve and has already thought through a sensible way forward.
Guided care paths simplify complexity and build consumer trust
Predeveloped care paths and packaged offerings are one way health systems can meet this moment. When thoughtfully designed, they do not oversimplify care or constrain clinical judgment. Instead, they translate complexity into something consumers can grasp. A musculoskeletal pathway, a women’s health navigation experience, or a behavioral health onboarding sequence does not eliminate individualized decision-making; it frames it. It signals that the system is prepared to guide the patient through more than a single encounter.
Importantly, this approach does not need to be payer-directed. While bundled care has historically been associated with value-based reimbursement arrangements, HSA-driven consumer behavior creates a parallel opportunity. When care is pre-deductible, consumers are not deferring to network rules or prior authorization. They are making judgments about whether the care experience feels credible, predictable, and worth the investment. Health systems that can articulate value directly to consumers at this stage are not circumventing payers; they are engaging patients earlier in the journey.
Technology can support this engagement, but it should not define it. AI-enabled navigation tools can help consumers articulate concerns and understand options, but their greatest value lies in guiding people toward well-designed care paths rather than fragmenting decisions further. Used this way, AI complements what health systems already do best: applying clinical judgment, coordinating care, and building trust over time.
Design access that respects consumer decisions
Consumers are more self-directed, more financially responsible, and more informed than they were even a decade ago. They are willing to engage with care earlier when they can see the shape of what lies ahead. Systems that respond by presenting coherent paths—rather than isolated services—will be better positioned to earn that engagement.
The next front door in health care will be defined by whether consumers feel that the system understands how they make decisions and respects the fact that many are now spending their own dollars. Health systems that design access around that truth will not only remain relevant in a direct-to-consumer economy; they will help define it.
Mark Lutes
Mark Lutes is Chair of Epstein Becker Green’s Board of Directors. He is trusted by private equity sponsors to help them understand the impact of regulatory compliance concerns on their healthcare industry investments, Mark also provides strategic counsel for large hospital systems in their mergers, acquisitions, and joint ventures. Clients rely on his insight into evolving state and federal health care finance and policy trends to structure transactions with other hospital systems, physician groups, and managed health care plans. Through the firm's affiliate, EBG Advisors, and National Health Advisors, Mark offers strategic counsel in health policy and on health care reimbursement changes.
Richard Hughes IV
Richard Hughes is a multi-talented health lawyer, strategic advisor, advocate, and teacher.
His thought leadership and problem-solving strategies have broken barriers to access for vaccines and medicines. His advice on legal and policy solutions is sought after by leading biopharmaceutical companies, industry trade associations, investors, patient advocacy organizations, members of Congress, and federal agencies.
Richard's practice emphasizes vaccines, prevention, and early intervention. Health care and life sciences clients value his guidance and counsel on legal, regulatory, and policy issues, as well as his ability to assemble multidisciplinary consulting teams to offer strategic business advice and build market development strategies.
Richard returned to Epstein Becker Green after serving as Managing Director at a leading Washington health care advisory firm and Vice President at a major vaccine manufacturer during the COVID-19 pandemic.
Jeff Brown
Jeff Brown is Practice Leader – Insurance + Risk Strategies at EBG Advisors, where he brings extensive expertise in product innovation, payer economics, provider collaboration and market strategy. In prior leadership roles at a major payer, he managed a multi-billion-dollar portfolio of health and insurance P&Ls through phases of market entry, growth, and performance turnaround, shaping benefit structures and pricing strategies that influence healthcare access.
