May 2026
Diana Craig, Director Benefits Compliance
On January 29, 2026, the U.S. Department of Health and Human Services (“HHS”) released the maximum limits on cost sharing for 2027 plan years under the Affordable Care Act (“ACA”) for in-network Essential Health Benefits (“EHBs”).
For 2027 plan years, the limitation on cost sharing is $12,000 for self-only coverage and $24,000 for family coverage. This is a 13.2% increase from 2026 cost-sharing limits of $10,600 for self-only coverage and $21,200 for family coverage. The ACA’s cost-sharing limit for self-only coverage applies to each individual enrolled in family coverage, which requires health plans to embed an individual out-of-pocket maximum (“OOPM”) into family coverage designs. Note that health savings accounts (“HSAs”) compatible with high-deductible health plans (“HDHPs”) must comply with lower limits on out-of-pocket costs.
Employer action items
- Review 2027 plan designs with insurers and third-party administrators (“TPAs”) to confirm that in-network out-of-pocket maximums for Essential Health Benefits do not exceed the 2027 ACA limits, including proper embedding of the individual out-of-pocket maximum within family coverage tiers.
- Coordinate with advisors or vendor partners about HDHP compliance to ensure any HSA-compatible plans continue to satisfy the lower, IRS-imposed out-of-pocket limits, which differ from the ACA maximums and may require separate monitoring during the 2027 plan design process.
Additional information and resources
For more information
We’re ready when you are. Get in touch and a friendly, knowledgeable Baldwin advisor is prepared to discuss your business or individual needs, ask a few questions to get the full picture, and make a plan to follow up.
This document is intended for general information purposes only and should not be construed as advice or opinions on any specific facts or circumstances. The content of this document is made available on an “as is” basis, without warranty of any kind. The Baldwin Insurance Group Holdings, LLC (“The Baldwin Group”), its affiliates, and subsidiaries do not guarantee that this information is, or can be relied on for, compliance with any law or regulation, assurance against preventable losses, or freedom from legal liability. This publication is not intended to be legal, underwriting, or any other type of professional advice. The Baldwin Group does not guarantee any particular outcome and makes no commitment to update any information herein or remove any items that are no longer accurate or complete. Furthermore, The Baldwin Group does not assume any liability to any person or organization for loss or damage caused by or resulting from any reliance placed on that content. Persons requiring advice should always consult an independent adviser.
The Baldwin Group offers insurance services through one or more of its insurance licensed entities. Each of the entities may be known by one or more of the logos displayed; all insurance commerce is only conducted through The Baldwin Group insurance licensed entities. This material is not an offer to sell insurance.
