2027 Health Plan Limits: ACA Out-of-Pocket Maximums, HDHP and HSA Thresholds, and EBHRA Contribution Caps

By: HUB’s EB Compliance Team

Recently, the IRS, DOL and HHS released certain annual adjustments for 2027 plan years. The adjustments include the largest one-year increase to the Affordable Care Act (ACA) out-of-pocket maximum (OOPM) in more than a decade — a $1,400 jump for self-only coverage. High-deductible health plan (HDHP) thresholds and health savings account (HSA) contribution limits rose modestly, and the excepted benefit health reimbursement arrangement (EBHRA) limit was increased by $50. The current 2026 limits and new 2027 limits are illustrated in the table below.

Summary of 2027 limits

ACA out-of-pocket maximums

Under the ACA, non-grandfathered group health plans — fully insured, self-insured and level-funded — must cap annual in-network cost sharing on essential health benefits (EHB) at amounts set each year by the Department of Health and Human Services (HHS). For plan years beginning on or after January 1, 2027, those limits are $12,000 for self-only coverage and $24,000 for other than self-only (family) coverage.

These figures represent an approximately 13.2% increase over the 2026 limits of $10,600 and $21,200. The unusually large adjustment reflects CMS’s revised premium adjustment percentage methodology — finalized in the 2025 Patient Protection and Affordable Care Act; Marketplace Integrity and Affordability final rule. The methodology change produces significantly higher OOPM ceilings than the prior approach.

Plan sponsors should note that the ACA OOPM also requires an embedded individual out-of-pocket limit for any enrollee with family coverage. Each covered individual’s accumulator must stop at the self-only OOPM ($12,000 for 2027), even if the family OOPM has not yet been satisfied.

HDHP minimum deductibles and out-of-pocket maximums

To qualify as an HSA-eligible high-deductible health plan (HDHP), a plan must meet both minimum deductible and maximum out-of-pocket thresholds set annually by the IRS.

The HDHP OOPM is set separately from — and is significantly lower than — the ACA OOPM. A plan sponsor that wants to offer HSA-qualified coverage must use the lower HDHP figure as the ceiling for in-network EHB cost sharing. Stated differently, the ACA OOPM is the maximum any non-grandfathered plan may impose; the HDHP OOPM is the maximum an HSA-qualified plan may impose. The gap between the two ($3,300 for self-only and $6,600 for family in 2027) widened materially this year and gives plan sponsors more room to design non-HDHP options with higher cost sharing if desired.

HSA contribution limits

For calendar year 2027, the annual HSA contribution limits are $4,500 for self-only HDHP coverage and $9,000 for family HDHP coverage. The catch-up contribution for HSA-eligible individuals age 55 or older remains $1,000, a statutory amount not subject to inflation indexing.

Several recurring administrative points warrant attention as plan sponsors communicate the new limits:

Family limit applies to any coverage other than self-only. All tiers of coverage that result in more than one individual being covered (employee + child, employee + spouse, family, etc.) use the $9,000 limit. When either spouse has family HDHP coverage, the $9,000 family limit is shared between them and may be divided in any agreed allocation; it cannot be doubled..

Catch-up contributions are individual. When both spouses are age 55 or older, each spouse may make a $1,000 catch-up contribution to their own HSA. Catch-up contribution amounts for two individuals cannot be combined into a single account.

Mid-year HDHP enrollment. Individuals enrolled in HDHP coverage on December 1, 2027, may contribute up to the full annual contribution limit under the last-month rule, subject to the 13-month testing period. Individuals rather than employers are responsible for determining their own eligibility to use the last-month rule.

EBHRA contribution limit

For plan years beginning in 2027, the maximum amount that may be made newly available under an excepted benefit health reimbursement arrangement (EBHRA) is $2,250, up $50 from the 2026 limit of $2,200. More information on EBHRAs can be found here and here.

Conclusion

The 2027 limits reflect modest increases for HSAs, HDHPs and EBHRAs alongside a notable jump in the ACA OOPM driven by CMS’s revised premium adjustment percentage methodology. Plan sponsors should incorporate the new figures into 2027 plan designs, payroll systems and participant communications well in advance of the plan year.

If you have any questions, please contact your HUB advisor. View more compliance articles in our Compliance Directory.

NOTICE OF DISCLAIMER:

Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore, they cannot provide legal or tax advice. The information herein is provided for general information only and is not intended to constitute legal or tax advice as to an organization’s or individual’s specific circumstances. It is based on HUB International’s understanding of the law as it exists on the date of this publication. Subsequent developments may result in this information becoming outdated or incorrect and HUB International does not have an obligation to update this information. You should consult an attorney, accountant or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your or your organization’s particular needs.