Health Plan Cost-sharing Limits for 2027 Plan Years Are Released
Posted February 13, 2026
On Jan. 29, 2026, the U.S. Department of Health and Human Services (HHS) announced the Affordable Care Act (ACA) maximum cost‑sharing limits for the 2027 plan year. The limits will increase to $12,000 for self-only coverage and $24,000 for family coverage, representing an approximate 13.2% increase from the 2026 limits. Employers should review their health plan designs annually to ensure compliance with these updated requirements.
ACA Out‑of‑Pocket Maximum (OOPM)
Most non-grandfathered health plans—including fully insured, self‑insured, and level‑funded plans—must comply with annual out‑of‑pocket maximums for essential health benefits (EHBs). EHBs include services such as emergency care, hospitalization, outpatient services, maternity and newborn care, pediatric services and prescription drugs.
Once an enrollee reaches the annual OOPM, no additional cost sharing may be applied to covered EHBs for the remainder of the plan year. The OOPM includes deductibles, copayments and coinsurance, but does not include premiums or costs for noncovered services. Plans with provider networks are not required to count out‑of‑network expenses toward the OOPM.
Embedded OOPM Requirements
Under the ACA, the self‑only OOPM must apply to each individual enrolled in a family plan. This means that if the family OOPM exceeds the self‑only limit of $12,000 in 2027, the plan must include an embedded individual OOPM that does not exceed this threshold. Employers should ensure that their plan designs either remain below the ACA limits or include an embedded structure that meets these requirements.
High Deductible Health Plans (HDHPs)
HSA‑compatible high deductible health plans are subject to separate federal limits on out‑of‑pocket costs. The IRS has not yet released the OOPM limits for 2027. For the 2026 plan year, HDHP OOPMs are capped at $8,500 for self‑only coverage and $17,000 for family coverage.
Summary
The ACA’s updated cost‑sharing limits for 2027 will require employers to review their medical plans to ensure compliance, particularly with respect to out‑of‑pocket maximums and embedded OOPM requirements. Employers offering HDHPs should also monitor IRS updates for forthcoming 2027 guidance.
