Federal agencies have released the Affordable Care Act (ACA) and IRS indexed limits applicable to plan years beginning on or after January 1, 2027. Given the significant increase in the ACA Maximum Out-of-Pocket (MOOP) limits for 2027, employers should carefully evaluate whether increasing member cost-sharing aligns with their benefit strategy and employee affordability objectives. For clients offering HSA-qualified HDHPs, the IRS limits will continue to be the primary plan design constraint, as they remain substantially lower than the ACA maximums.
This update is intended for informational purposes and should not be construed as legal or tax advice. Employers should consult their benefits advisor, legal counsel, or compliance partner regarding specific plan design decisions.
