The 2027 Numbers Are Out: What Changes for Employer Health Plans
By the PlanVantage engine teamPublished September 15, 20266 min read
Between May and September the agencies published nearly every figure a 2027 plan year runs on, and a few of them moved further than usual. The ACA out-of-pocket ceiling took its largest step ever, the affordability percentage crossed 10 percent for the first time, and Medicare Part D retired the creditable coverage test most group plans had been leaning on. This is the working list, with the source for each number, in the order a renewal meets them.
HSA and HDHP Limits for 2027
IRS Rev. Proc. 2026-24, released May 29, 2026, set the 2027 figures. HSA contributions rise to $4,500 self-only and $9,000 family (from $4,400 and $8,750). The HDHP minimum deductible rises to $1,750 self-only and $3,500 family, and the HDHP out-of-pocket ceiling to $8,700 and $17,400. The $1,000 catch-up at age 55 does not index. The excepted-benefit HRA cap moves to $2,250.
Where it bites: any family HDHP with an embedded individual deductible below $3,500, and any plan that sat at the 2026 $8,500 out-of-pocket edge. Both need a design change or a new SBC, not just a new number in the rate sheet.
The ACA Out-of-Pocket Ceiling Jumps 13 Percent
For plan years beginning in 2027 the maximum annual limitation on cost sharing is $12,000 for self-only coverage and $24,000 for other than self-only, up from $10,600 and $21,200. CMS published the figures on January 29, 2026 with a premium adjustment percentage of 1.8916, which measures private premium growth since 2013. It is the largest one-year increase in the ceiling since the ACA took effect, and it applies to every non-grandfathered group plan, insured or self-funded, of any size.
Carriers and TPAs will move plan out-of-pocket maximums up to the new ceiling where they can. A $1,400 single and $2,800 family increase is a benefit cut, and it shows up in the actuarial value, in the contribution modeling, and in what employees read at open enrollment. Treat a renewal that quietly adopts the new ceiling as a plan design change and price it as one.
Affordability at 10.22 Percent, Penalties Up 13 Percent
Rev. Proc. 2026-26 (July 21, 2026) set the required contribution percentage for plan years beginning in 2027 at 10.22 percent, up from 9.96. Under the federal poverty line safe harbor, using the 2026 guideline of $15,960 for a one-person household, the employee-only contribution for the lowest-cost minimum value plan can be as high as $135.93 a month for a 2027 calendar-year plan, against $129.89 in 2026.
The penalties indexed with the same factor. Rev. Proc. 2026-22 puts the 2027 employer shared responsibility amounts at $3,780 per full-time employee for failing to offer coverage and $5,670 per affected employee for coverage that is unaffordable or below minimum value, up from $3,340 and $5,010. A 200-employee employer that misses the 95 percent offer test in 2027 is looking at roughly $642,600 before any defense.
Medicare Part D: A Higher Cap and a Harder Creditable Test
The 2027 Rate Announcement (April 6, 2026) sets the Part D deductible at $700 and the out-of-pocket cap at $2,400, up from $615 and $2,100. The base beneficiary premium for 2027 is $41.33, the full 6 percent the statute allows.
The change that reaches every group plan is the creditable coverage test. For 2027 plan years the original simplified determination method, the design-based checklist most non-RDS plans have used since 2009, is no longer available. A plan is creditable if it pays on average at least 73 percent of participants' prescription drug expenses under the revised simplified method, or if an actuarial determination says so. Plans with high Rx deductibles or heavy coinsurance that passed in 2026 can fail in 2027, which exposes Medicare-eligible employees to a late enrollment penalty the notice was meant to prevent. One relief: HRAs, health FSAs and HSAs are exempt from the Part D notice and CMS disclosure for 2027.
Run the determination, do not assume it
The 73 percent figure is an actuarial value of the drug benefit alone, measured against a Part D population. It is not the plan's overall AV and it is not the medical carrier's word. PlanVantage's Creditable Coverage module computes it for each plan design so the notice can go out with a number behind it.
Telehealth Before the Deductible Is Permanent
The 2025 reconciliation act made the HDHP telehealth safe harbor permanent, and IRS Notice 2026-05 (December 9, 2025) confirmed it applies to plan years beginning after December 31, 2024. An HDHP can cover telehealth and other remote care before the deductible without disqualifying HSA contributions, with no sunset to watch. Plans that dropped first-dollar telehealth in early 2025 can put it back for 2027. Check that the plan document draws the line where the notice does: remote care, not mailed prescriptions or devices.
Mental Health Parity: The Rule Is Paused, the Statute Is Not
The 2024 MHPAEA final rule remains unenforced while the agencies write a replacement; in a March 30, 2026 court filing they committed to a new proposed rule by the end of 2026. On September 8, 2026 the Labor Department issued Field Assistance Bulletin 2026-03, which narrows nonquantitative treatment limitation enforcement to three priorities: exclusions and separate limits that apply only to mental health and substance use benefits, medical necessity and utilization review standards, and network composition and reimbursement. The 2013 rule and the statutory requirement to produce a written comparative analysis within ten business days of a request are fully in force. Self-funded clients should have the analysis on the shelf, and should read the three priorities as the table of contents for the next audit letter.
PBM Reform Is Law, With a 2029 Start
The Consolidated Appropriations Act, 2026, signed February 3, 2026, requires pharmacy benefit managers to pass 100 percent of rebates, fees and other manufacturer remuneration through to the plan, to report drug-level claims and spread semiannually to plans with 100 or more participants, and to disclose their compensation. Bona fide service fees that are fixed and at fair market value are the exception. The requirements apply to plan years beginning 30 months after enactment, which for calendar-year plans means January 1, 2029. PBM contracts being signed for 2027 will still be running when the mandate arrives, so pass-through and reporting language belongs in this year's RFP, and fiduciaries should be documenting now that PBM compensation is reasonable.
ICHRA Has a New Name and the Same Rules
On September 3, 2026 CMS and the Small Business Administration began marketing individual coverage HRAs as CHOICE Arrangements. Nothing in the regulation changed: the classes, the affordability test, the 90-day notice and the Form 1095-C codes are the ICHRA rules they were in 2025. Clients will hear the new name from carriers this fall and assume a new product launched. It is the same arrangement with a federal marketing push behind it, and the same open question about how brokers are compensated on individual-market placements.
Before the 2027 Renewals Go Out
- • Re-check every HDHP against the $1,750 / $3,500 deductible floor and the $8,700 / $17,400 ceiling.
- • Price any move of the plan out-of-pocket maximum toward $12,000 / $24,000 as a design change, with its actuarial value.
- • Reset the FPL safe-harbor contribution to $135.93 a month for calendar-year 2027 plans, or the W-2 and rate-of-pay equivalents at 10.22 percent.
- • Run the Part D creditable coverage determination at 73 percent for every plan with a Medicare-eligible population, before the October notice.
- • Confirm the written MHPAEA comparative analysis exists and covers the three priorities in FAB 2026-03.
- • Put pass-through and reporting terms in every PBM contract that will still be in force on January 1, 2029.
- • Still to come: the 2027 health FSA limit and the PCORI fee for plan years ending after September 30, 2026, both expected from the IRS in the fourth quarter.
PlanVantage's plan design checks already carry the 2027 HSA, HDHP and ACA out-of-pocket limits, and its Creditable Coverage module tests each plan against the 73 percent threshold, so the plans you build this fall are checked against next year's rules. Request a demo to see it on your own plans.