The Affordable Care Act (ACA) continues to impact employer-sponsored health plans through annual updates to cost-sharing limits, reporting requirements, affordability thresholds and preventive care guidelines. Use this checklist to review key ACA requirements for the 2027 plan year and update plan documents, employee communications and compliance procedures as needed.
Plan Design
☐ Review Out-of-Pocket Limits
For plan years beginning in 2027, the ACA maximum out-of-pocket limit for essential health benefits is:
- $12,000 for self-only coverage
- $24,000 for family coverage
For HSA-compatible HDHPs, the 2027 maximum is lower:
- $8,700 self-only
- $17,400 family
☐ Review Health FSA Limits
Confirm employee salary-reduction contributions do not exceed the 2027 IRS limit. The 2027 contribution and carryover limits have not yet been released.
For reference, the 2026 limits are $3,400 for contributions and $680 for carryovers.
☐ Review Preventive Care Coverage
Non-grandfathered plans must cover certain recommended preventive services without cost sharing when provided in-network. Review the latest guidelines and update coverage as necessary, including changes to preventive services such as cervical cancer screening.
☐ Review Excepted Benefit HRA Limits
For 2027, the maximum benefit under an excepted benefit HRA is $2,250.
☐ Confirm Grandfathered Status
If your plan is grandfathered:
- Determine whether it will retain that status for 2027.
- If status is lost, ensure the plan complies with additional ACA requirements for non-grandfathered plans.
- If status is retained, continue including the required grandfathered-plan notice in applicable plan materials.
Employer Mandate
☐ Determine ALE Status
Determine whether your organization is an applicable large employer (ALE) for 2027. Generally, ALE status applies to employers with 50 or more full-time employees, including full-time equivalents, during the preceding calendar year.
☐ Offer Coverage to Full-Time Employees
ALEs generally must offer affordable, minimum-value coverage to full-time employees and their dependent children or potentially face penalties.
For ACA purposes, a full-time employee generally works at least 30 hours per week or 130 hours per month.
☐ Confirm Coverage Is Affordable
For 2027, the ACA affordability percentage increases to 10.22%, up from 9.96% in 2026.
ALEs may use one of the IRS affordability safe harbors—W-2, rate of pay or federal poverty level—to determine affordability.
For calendar-year plans using the federal poverty level safe harbor, the maximum employee contribution is approximately $135.93 per month for 2027.
☐ Confirm Minimum Value
Coverage must generally pay at least 60% of the total allowed cost of benefits to meet the ACA’s minimum-value standard. Employers can use an IRS minimum-value calculator, design-based safe harbor or actuarial certification.
☐ Review Potential Employer Mandate Penalties
For 2027:
- Section 4980H(a): $3,780 annually per applicable full-time employee, subject to the applicable reduction.
- Section 4980H(b): $5,670 annually for each full-time employee receiving an Exchange subsidy because coverage is unaffordable or does not provide minimum value.
ACA Reporting
☐ Determine Reporting Requirements
ACA reporting generally applies to:
- Self-funded plans: Section 6055 reporting
- ALEs: Section 6056 reporting, whether fully insured or self-funded
- ALEs with self-funded plans: Both requirements apply and can generally be combined on Forms 1094-C and 1095-C.
Non-ALE employers with fully insured plans generally are not subject to these ACA reporting requirements.
☐ File ACA Returns
For 2026 calendar-year reporting:
- Electronic filing deadline: March 31, 2027
- Paper filing deadline: March 1, 2027, for employers eligible to paper file
Most employers must file electronically. An automatic 30-day extension may be available by filing Form 8809.
☐ Notify Individuals About 1095-B/1095-C Availability
Employers generally no longer have to automatically provide Forms 1095-B or 1095-C. Instead, they may provide them upon request if required notice procedures are followed.
By March 2, 2027, post a clear notice explaining how individuals can request their statement and keep the notice available through October 15, 2027.
PCORI Fees
☐ Pay PCORI Fees for Self-Funded Plans
Employers with self-funded health plans generally must pay PCORI fees using Form 720.
For plan years ending in 2026, the 2027 deadline is August 2, 2027.
For fully insured plans, the insurer is generally responsible for paying the fee.
Required Notices and Disclosures
☐ Update the Summary of Benefits and Coverage (SBC)
Provide an updated SBC with 2027 enrollment materials and generally at least 30 days before the new plan year when coverage automatically renews.
☐ Provide Exchange Notices to New Hires
Provide applicable new hires with the required written notice about the ACA Health Insurance Marketplace. Employers may use the Department of Labor’s model notices.
☐ Provide Patient Protection Notices
If the plan requires participants to designate a primary care provider, include the required patient protection notice with applicable plan materials.
☐ Update the Summary Plan Description (SPD)
Reflect any 2027 changes to benefits in an updated SPD or Summary of Material Modifications (SMM), as applicable.
Final Review
Before the 2027 plan year begins, confirm that:
- ☐ Plan limits have been updated
- ☐ Employee contributions meet affordability requirements
- ☐ Coverage meets minimum-value requirements
- ☐ Preventive care coverage reflects current guidelines
- ☐ ALE status has been determined
- ☐ ACA reporting responsibilities are assigned
- ☐ Required notices and disclosures are updated
- ☐ SBC and SPD/SMM materials reflect 2027 plan changes
- ☐ PCORI obligations are addressed
