Association Health Plans After the 2024 Rescission: What Self-Employed Workers Can Still Join

If you went looking for an association health plan in the last few years, you probably found two kinds of articles. The older ones describe a wide-open option where any group of freelancers can band together and buy coverage like a big employer. The newer ones say the whole thing got killed. Neither is right.

Here is what actually happened, and what is still available if you are self-employed.

The 2018 rule is gone. Association health plans are not.

In 2018 the Department of Labor issued a rule that dramatically widened who could form an association health plan. Self-employed people with no employees, so-called working owners, could join. Groups could form on geography alone, meaning a chamber of commerce in your city could sell coverage to almost anyone nearby.

Eleven states and the District of Columbia sued. A district court struck down key parts of the rule in 2019, and the DOL finalized a rescission of the 2018 regulation on April 29, 2024. The appeal was dismissed the following month.

The part most write-ups miss: rescinding the 2018 rule did not outlaw association health plans. It returned them to the pre-2018 DOL guidance that governed them for decades. The DOL itself noted it was unaware of any AHPs operating in reliance on the 2018 rule, which tells you how little was actually built on it before it fell.

So AHPs still exist. The bar to join one is just higher, and narrower, than the 2018 version promised.

What the older standard actually requires

Under pre-2018 guidance, an association has to look like a genuine organization rather than an insurance-buying vehicle assembled for the occasion. In practice that means:

A real purpose beyond insurance. Trade associations, professional bodies and industry groups qualify. A group formed last quarter to sell health plans does not.
A commonality of interest. Members share a trade, industry or profession. Same-city is generally not enough on its own.
Member control. The people in the association, not the insurer or a marketing company, direct it.

Meet that and the association can be treated as a single large employer. That is the whole point, because large-group plans are not bound by the ACA’s individual and small-group rating rules.

Why 1099 workers care about the large-group distinction

On the individual market your premium is set by age, location, tobacco use and family size. Health is not a factor. That sounds like a good deal, and if you have chronic conditions or you qualify for a subsidy, it usually is.

If you are a healthy 34-year-old contractor earning too much for a subsidy, it is the opposite. You are paying a community-rated premium that averages in everyone else’s claims, with no way to price your own risk.

Large-group and underwritten association plans work differently. They can look at the health of the group, and they frequently carry nationwide PPO networks rather than the narrow HMO networks that dominate many state exchanges. If you travel for work, spend part of the year in another state, or simply want to keep a specialist who is out of network on every Marketplace plan in your county, that network difference is often the entire decision.

The trade-off is real and you should weigh it honestly. Underwriting means you can be rated up or declined. Some association arrangements are not ACA-compliant plans at all and can exclude pre-existing conditions. Ask, in writing, whether the plan is major medical and whether it is guaranteed issue.

Who actually qualifies now?

This is where most people get stuck, because the answer depends on facts about your business that you may not have thought about.

You likely have a path if:

You have at least one W-2 employee besides yourself, which can make you a small employer rather than an individual
You belong to a legitimate trade or professional association in your field
Your spouse is on payroll in a genuine role, documented properly

You likely do not if:

You are a solo 1099 contractor with no employees and no trade association membership
The only “association” on offer was created by the agency selling you the plan

That last point deserves emphasis. The self-employed-with-no-employees case is exactly what the 2018 rule tried to open up and exactly what the rescission closed. If someone is selling you an AHP as a sole proprietor with no staff, ask precisely which association you are joining and how long it has existed.

Because eligibility turns on these details, this is one of the few areas of personal finance where an independent broker earns their keep. Brokers are paid by the carrier, so the plan costs the same whether you use one or not, and they can see which association plans are genuinely open to you in your state. A good one runs your eligibility before quoting anything, which is the correct order. Custom Health Plans, a brokerage in Plano, Texas, works this way with 1099 contractors and small employers.

How this stacks up against the alternatives

Option	Health questions?	Network	Subsidy eligible?	Best fit
Marketplace (on-exchange)	No	Often narrow HMO	Yes, if income qualifies	Subsidy-eligible, or pre-existing conditions
Off-exchange private	No	Often broader PPO	No	Over the subsidy threshold, wants network
Association health plan	Usually yes	Often nationwide PPO	No	Healthy, has employees or genuine association
Short-term	Yes	Varies	No	Bridging a defined gap
Health share ministry	Yes, plus conduct rules	Varies	No	Comfortable with no legal guarantee

One caution on short-term plans, since they come up constantly in this conversation. A 2024 federal rule capped new short-term policies at three months with a four-month maximum including renewals. In August 2025 the administration announced it would not prioritize enforcement. State law still governs, and the practical availability varies a lot by state, so what you can buy today depends on where you live and which carriers have responded.

The honest summary

Association health plans are a narrower option than the 2018 coverage suggested, and a real one that a lot of self-employed people wrongly believe was abolished. If you have employees or belong to a genuine trade association, they are worth pricing against an off-exchange PPO. If you are a solo contractor with neither, your realistic choices are the Marketplace, off-exchange private coverage, or a short-term bridge.

Run the numbers with your actual expected income before deciding. If a subsidy is on the table, it usually beats everything else on this list.

This article is educational and is not legal, tax or insurance advice. Eligibility rules vary by state and by plan. Confirm your own situation with a licensed professional before enrolling.

This post may contain affiliate links.

More Recommended Ebike/Scooters

Check out these other ebikes and scooters I've reviewed:

Urban Arrow Ebike – Last year, I made one of the largest purchases I’ve ever made – I bought a $9,000 electric cargo bike from Urban Arrow. In my Urban Arrow review, I will discuss what it is and why I decided to buy this bike, as well as discuss how impactful a bike like this can be on your journey to financial independence.
Troxus Explorer Step-Thru Ebike – The Troxus Explorer Step-Thru is a fat-tire ebike that I’ve had the pleasure of riding for a while now. It has amazing power, great looks, and awesome range. If you’re looking for a great fat-tire ebike that offers a lot for the price, the Troxus Explorer Step-Thru is definitely one for you to consider. Check out my Troxus Explorer Step-Thru Review.
Hovsco HovBeta Ebike – The HovBeta is a folding ebike with great specs and a lot of interesting features, and importantly, it’s sold at a good price point. I’ve had a blast commuting with it and using it to do deliveries with DoorDash, Uber Eats, and Grubhub. Check out my Hovsco HovBeta Ebike Review.
Vanpowers Manidae Ebike – The Vanpowers Manidae is a fat tire ebike that I’ve been riding as my primary winter commuting bike and have also been using it to do food delivery with apps like DoorDash, Uber Eats, and Grubhub. After clocking in a decent number of miles with this ebike, I wanted to write a post sharing what my experience with the Vanpowers Manidae ebike has been like. Check out my Vanpowers Manidae Review.
Sohamo S3 Step-Thru Folding EBike Review – A Great Value Folding Ebike – The Sohamo S3 Step-Thru Folding Ebike is an entry-level folding ebike that offers a lot of value for the price point. I’ve been riding the Sohamo S3 for a while now, putting the bike through its paces, and I have to say, this bike has exceeded all of my expectations. Check out my Sohamo Review.
KBO Flip Ebike – The KBO Flip is an excellent bike. I’ve had a great time riding it and think it’s a versatile bike that can be used for a lot of purposes and can fit a variety of lifestyles. It’s worked out great for me as a general commuter bike and as a food delivery bike. Check out my KBO Flip Review.
Hiboy P7 Commuter Ebike – The Hiboy P7 is an excellent electric commuter bike that’s offered at an affordable price point. The range and speed of this bike are both very good, so you won’t have any trouble getting anywhere you need to go with it. As a food delivery vehicle, this is also good – with how much range it offers, you’ll be able to work all day on a single charge. Check out my Hiboy P7 Commuter Electric Bike Review.
Himiway Escape Ebike – The Himiway Escape is an interesting bike for anyone looking for a moped-style ebike. If you’re a gig economy worker, the Himiway Escape is particularly interesting and it’s possible to think of it as an investment, especially if you can opt to do deliveries with the Himiway versus using a car. It’s not cheap, but you can definitely make your money back when you compare the mileage you’ll put on your car versus using an ebike. Check out my Himiway Escape Bike Review.
Espin Sport Ebike – The Espin Sport is a good ebike for someone who is looking for an ebike that feels and rides more like a regular bike. There are many ebikes that are really only bikes in name. In reality, they’re basically electric mopeds. The Espin Sport, by contrast, is a bike you could probably ride without the battery and you’d feel like you’re just riding a regular bike. Check out my Espin Sport Review.
Varla Eagle One Scooter – The Varla Eagle One is an excellent scooter that can make sense for a lot of people. It can work as a primary mode of transportation. You can use it to work on gig economy apps like DoorDash, Uber Eats, and Grubhub. And it can also be a recreational vehicle if you’d prefer to use it for that. Check out my Varla Eagle One Review.
Varla Falcon Scooter – The Varla Falcon is an excellent scooter that offers a good amount of power at a lower price point compared to more powerful scooters. It’s not exactly an entry-level scooter, nor is it a high-powered scooter. I think it fits somewhere in-between those two categories – an intermediate scooter if I had to give it a category. Check out my Varla Falcon Review.
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Fucare H3 Scooter – The Fucare H3 is a fun scooter and I’ve enjoyed testing it out. For a daily commuter or quick trips or errands, the Fucare H3 is probably the scooter I’ll use. It’s portable and easy to maneuver, so it’s just easier to take on the road when I need it. Check out my Fucare H3 Scooter Review.

More Recommended Investing App Bonuses

For additional investing app bonuses, be sure to check out the ones below:

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Kevin is an attorney and the blogger behind Financial Panther, a blog about personal finance, travel hacking, and side hustling using the gig economy. He paid off $87,000 worth of student loans in just 2.5 years by choosing not to live like a big shot lawyer.

Kevin is passionate about earning money using the gig economy and you can see all the ways he makes extra income every month in his side hustle reports.

Kevin is also big on using the latest fintech apps to improve his finances. Some of Kevin's favorite fintech apps include:

SoFi Money. A really good checking account with absolutely no fees. You'll get a $25 referral bonus if you open a SoFi Money account with a referral link, and an additional $300 if you complete a direct deposit.
5% Savings Accounts. I'm currently getting 5.24% interest on my savings through a company called Raisin. Opening a Raisin account takes minutes to complete, it's free, and all of your funds are FDIC-insured. I explain how it works, why I'm now using it to store my emergency fund and any other cash savings I have, and why I recommend everyone check it out in this review.
US Bank Business. US Bank is currently offering new business customers a $400/$1200 signup bonus after opening a new account and meeting certain requirements.
M1 Finance. This is a great robo-advisor that has no fees and allows you to create a customized portfolio based on your risk tolerance. You also get $75 for opening an account.
Empower. One of best free apps you can use to monitor your portfolio and track your net worth. This is one of the apps I use to track my financial accounts.

Feel free to send Kevin a message here.