Open enrollment is an ideal time to review health plans, update benefits for 2027, and communicate any changes to employees. Employers should also ensure required notices and updated plan documents, such as summary plan description (SPD), summary of material modifications (SMM), or summary of benefits and coverage (SBC) are distributed as needed.
Use this checklist to prepare for a compliant and successful 2027 open enrollment season.
Plan Design Changes
Before open enrollment begins, employers should confirm their health plans reflect all applicable updates for 2027.
Affordable Care Act (ACA) Affordability
Applicable large employers (ALEs) must continue to offer affordable, minimum-value coverage to full-time employees and their dependents to avoid potential employer mandate penalties.
For plan years beginning in 2026, the adjusted affordability percentage is 9.96%. While the IRS has not yet released the ACA affordability percentage for 2027, employers should monitor future guidance and review their affordability safe harbor strategies to ensure compliance once the new percentage is announced.
Out-of-Pocket Maximum
For 2027 plan years, the ACA's maximum out-of-pocket limits are:
- $12,000 for self-only coverage
- $24,000 for family coverage
Employers should verify that plan cost-sharing limits comply with these thresholds and ensure family coverage includes an embedded individual out-of-pocket maximum when required.
Preventative Care Benefits
Non-grandfathered health plans must continue covering recommended in-network preventive care with no cost sharing. Ahead of the 2027 plan year, employers should confirm their plans reflect the latest preventive care updates, including newly effective screening guidelines.
HDHP and HSA Limits
Organizations offering high deductible health plans (HDHPs) should update plan documents and employee communications to reflect the new 2027 limits:
|
HSA/HDHP Limits |
||||
|
Type of Limit |
2026 |
2027 |
Change |
|
|
HSA Contribution Limit |
Self-only |
$4,400 |
$4,500 |
Up $100 |
|
Family |
$8,750 |
$9,000 |
Up $250 |
|
|
HSA Catch-up Contributions (not subject to adjustment for inflation) |
Age 55 or older |
$1,000 |
$1,000 |
No Change |
|
HDHP Minimum Deductible |
Self-only |
$1,700 |
$1,750 |
Up $50 |
|
Family |
$3,400 |
$3,500 |
Up $100 |
|
|
HDHP Maximum Out-of-pocket Expense Limit (deductibles, copayments and other amounts, but not premiums) |
Self-only |
$8,500 |
$8,700 |
Up $200 |
|
Family |
$17,000 |
$17,400 |
Up $400 |
|
Health FSAs and EBHRAs
Health FSA contributions remain subject to an annual IRS limit, which was $3,400 for 2026 and has not yet been announced for 2027. Employers should watch for the updated limit, ensure employee elections stay within it, and communicate the new amount during open enrollment.
EBHRA Limit
An excepted benefit health reimbursement arrangement (EBHRA) is an employer-funded, tax-free account that helps employees pay eligible out-of-pocket medical expenses. For 2027, the maximum annual contribution increases to $2,250, so employers should set their contribution amount and communicate the benefit during open enrollment.
Wellness Programs: Surcharges/Rewards
Employers using health-related surcharges or rewards, such as tobacco-related incentives, should review their wellness programs carefully for 2027. To reduce compliance risk, any program should meet HIPAA nondiscrimination rules, include a reasonable alternative standard, and clearly explain that option in plan materials.
Mental Health Parity: Required Comparative Analysis for NQTLs
Mental Health Parity and Addiction Equity Act (MHPAEA) requirements remain a key enforcement focus. Employers should work with insurers or third-party administrators to confirm required comparative analyses of nonquantitative treatment limitations (NQTLs) are complete and current.
Consider Expanded Options for Fertility Benefits
As employee demand for fertility coverage continues to grow, employers may want to explore opportunities to add or expand fertility benefits. Federal agencies have proposed a new category of excepted fertility benefits that could provide additional flexibility beginning in 2027. Employers interested in enhancing fertility coverage should consult with carriers and benefit advisors to evaluate available options.
Open Enrollment Notices
Open enrollment is a convenient time to distribute many required employee notices. Employers should review enrollment packets to confirm all applicable notices are included. Depending on plan design, these may include:
- Summary of Benefits and Coverage (SBC)
- Medicare Part D Creditable Coverage Notice
- Children's Health Insurance Program (CHIP) Notice
- Initial COBRA Notice
- Summary Plan Description (SPD) updates or Summary of Material Modifications (SMMs)
- Notice of Patient Protections
- Grandfathered Plan Notice
- HIPAA Special Enrollment Notice
- HIPAA Privacy Notice
- Women's Health and Cancer Rights Act (WHCRA) Notice
- Summary Annual Report
- Wellness Program Notices
- Individual Coverage HRA (ICHRA) Notice, if applicable
Preparing early can help employers avoid compliance issues, support employees' benefit decisions, and ensure a smoother open enrollment experience for everyone. Download the 2027 Open Enrollment Checklist for more details.
Additional Resources
Revenue Procedure 2026-24, which includes inflation-adjusted limits for Health Savings Accounts (HSAs) and HDHPs for 2027
Model notices for group health plans, including the WHCRA notice
Model COBRA notices for group health plans
