The markets were the regions around Charleston; South Carolina; Cheyenne, Wyoming; Philadelphia; Houston; and Miami.

The average employer plan deductible for single coverage is about $1,800, and the typical deductible for low-cost silver plan coverage in the five markets reviewed was about $5,000 to $6,000, the analysts found.

"In Miami's marketplace, AmeriHealth Caritas and UnitedHealthcare set deductibles at $5,900," the analysts write.

A $5,900 deductible amounts to 16% of the annual income for individuals earning just above 250% of the federal poverty limit, which is now $39,125 for an individual in most states, the analysts estimate.

The analysts suggest that federal policymakers could ease the impact of deductibles on moderate-income workers by moving to base the ACA premium tax credit subsidy system on the benefit structure of relatively rich gold-level plans, rather than on lean silver plans.

Tying ACA exchange subsidies to gold plans would increase federal spending by about $15 billion per year, or about $750 per person with exchange plan coverage, the analysts estimate.

ACA metal level basics: HealthCare.gov and other Affordable Care Act public health insurance programs are supposed to serve as online supermarkets for health insurance.

Consumers can use exchange programs to shop for plans with standardized coverage levels and use ACA tax credits to pay the premiums.

Regulators have created four coverage "metal levels." The levels are based on how well plans cover the cost of the "essential health benefits" package, or standard benefits package.

A bronze plan is supposed to cover about 60% of the cost of the EHB package; a silver plan, about 70%; a gold plan, about 80%; and a platinum plan, about 90%.

Federal law ties silver plan subsidies to the cost of the second-lowest-cost silver plan in a market. In some cases, low-income consumers can use tax credit premium subsidies to get bronze coverage or the lowest-cost silver plan without paying anything for premiums out of their own pockets.

Implications: The new Commonwealth Fund paper could affect discussions in Washington about employer efforts to give workers "cash for coverage" through the individual coverage health reimbursement arrangement program and other health account programs.

The creators of the programs usually assume that workers will use the employer cash to pay for the individual coverage available through HealthCare.gov and state-based ACA public exchange programs.

Daniel Cruz and Greg Fann, actuaries, argued in September, in a paper distributed by the Paragon Health Institute, that one obstacle to expanding the ICHRA program is that the exchange plans in many markets have weak benefits and weak provider networks.

Related: Small employers need better ICHRA options, analyst says at Senate Finance hearing

Cruz and Fann suggested that ICHRAs could improve individual coverage quality, by causing issuers to market plans based on quality and out-of-pocket costs for care as well as premiums.

The new Commonwealth Fund paper may further increase policymakers' focus on exchange plan quality and out-of-pocket costs.