2027 Employee Benefits Update: What's New (Not the Usual Open Enrollment Checklist)
By Marsha C. Marrullier, REBC | Strategic Employee Benefits Advisor, ARCW Leavitt Insurance Group | September 1, 2026
The IRS and HHS have finalized next year's numbers, and a few federal provisions have shifted in ways that are actually worth knowing before your renewal conversations start. This isn't the standard "get ready for open enrollment" reminder — it's what's genuinely new for 2027.
ACA Affordability Jumps to 10.22% — the Highest It's Ever Been
For plan years beginning in 2027, the IRS raised the ACA affordability percentage to 10.22% of household income, up from 9.96% in 2026. That's not a small move — it's the highest this figure has ever been.
What that means in practice: you have more room to raise the employee-only contribution for your lowest-cost, minimum-value plan option while still meeting the federal affordability safe harbor. If you haven't revisited your 2027 contribution strategy with this in mind, now's the time.
One nuance worth flagging: this applies plan-year by plan-year. Non-calendar-year plans that start before 2027 still use the 9.96% threshold until their new plan year begins.
ACA Out-of-Pocket Maximums Are Climbing Too
The ACA's cap on total enrollee cost-sharing for essential health benefits rises to $12,000 for self-only coverage and $24,000 for family coverage for 2027 plan years.
Family plans need to embed an individual out-of-pocket maximum at or below $12,000 for each covered person, even when the family maximum is higher. And HDHPs still have to satisfy the lower, HSA-compatible limits — which, in most plan designs, is the tighter constraint anyway.
2027 HSA & HDHP Limits, Side by Side With 2026
| Limit Type | Coverage | 2026 | 2027 | Change |
|---|---|---|---|---|
| HSA Contribution Limit | Self-only | $4,400 | $4,500 | +$100 |
| HSA Contribution Limit | Family | $8,750 | $9,000 | +$250 |
| HSA Catch-Up (Age 55+) | All | $1,000 | $1,000 | No change |
| HDHP Minimum Deductible | Self-only | $1,700 | $1,750 | +$50 |
| HDHP Minimum Deductible | Family | $3,400 | $3,500 | +$100 |
| HDHP Max Out-of-Pocket | Self-only | $8,500 | $8,700 | +$200 |
| HDHP Max Out-of-Pocket | Family | $17,000 | $17,400 | +$400 |
Source: IRS Rev. Proc. 2026-24
Health FSA Limit Projected to Rise to $3,500
Mercer's cost-of-living projection puts the 2027 health FSA salary-reduction limit at $3,500, up from $3,400 in 2026. The IRS typically doesn't finalize FSA numbers until October or November, so treat this as the planning figure for now — we'll flag it the moment it becomes official.
Telehealth-HSA Compatibility Is Now Permanent
Here's a genuinely good one: the One Big Beautiful Bill Act made a pandemic-era exception permanent. HDHPs can waive the deductible for telehealth and other remote care — other than preventive care — without putting participants' HSA eligibility at risk. No sunset date. No annual renewal required.
This remains optional for plan sponsors, not mandatory. If your plan document hasn't been updated to reflect it, that's a conversation worth having with your carrier or TPA.
Excepted Benefit HRA Cap Increases
The maximum newly available EBHRA contribution rises to $2,250 for plan years beginning in 2027, up from $2,200.
Wellness Surcharges Are Facing New Legal Challenges
A wave of class-action suits is now targeting tobacco-use premium surcharges as HIPAA nondiscrimination violations. If your wellness program includes a health-contingent surcharge or reward, every plan material that references it needs to disclose a documented, reasonable alternative standard. Worth confirming yours is airtight before open enrollment materials go out the door.
Mental Health Parity Analyses: Still Required, Rule Rewrite Coming
Enforcement of the 2024 MHPAEA final rule is on hold, but the underlying requirement to conduct NQTL comparative analyses was never suspended — it's still a statutory obligation. Federal agencies have signaled a new proposed rule by the end of 2026, which could reshape these requirements heading into 2027. Confirm with your carrier or TPA that your comparative analyses are current.
None of This Has to Complicate Your Renewal
If you want to talk through what any of it means for your plan specifically, I'm one call away.
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Marsha C. Marrullier, REBC
Strategic Employee Benefits Advisor, ARCW Leavitt Insurance Group
Office: 754-315-5211 | Cell: 727-385-1067 | Marsha-Marrullier@Leavitt.com
This article is provided for general informational purposes only and does not constitute legal, tax, or benefits advice. Figures reflect IRS Rev. Proc. 2026-24 and HHS's 2027 cost-sharing release, current as of September 2026; the health FSA figure is a third-party cost-of-living projection pending official IRS confirmation. Please consult your legal or compliance advisor for guidance specific to your organization.