Benefits Decoder

What changed

Rules and figures that change what American employees pay for coverage. Dated, sourced, and short. We add an entry when something actually changes, which is a handful of times a year.

21 July 2026  ·  The subsidy cliff is confirmed for 2027

The IRS published the applicable percentage table for 2027 in Rev. Proc. 2026-26. It runs in the pre-2021 format and stops at "at least 300% but not more than 400%" of the federal poverty level. There is no percentage above 400%, which means that under current law the subsidy cliff applies for plan year 2027: a dollar of income over the line takes the premium tax credit to zero rather than tapering it.

The same document sets the employer coverage affordability threshold at 10.22% for 2027, up from 9.96% for 2026. A higher threshold means an employer may charge you more for self-only coverage before that coverage counts as unaffordable, which is the test that decides whether you are locked out of marketplace subsidies.

Check where the cliff sits for your household

16 July 2026  ·  Court pauses part of the 2027 marketplace rule

A federal court in Maryland stayed eight provisions of the 2027 Notice of Benefit and Payment Parameters, among them a provision that would have allowed higher out-of-pocket maximums on certain bronze and catastrophic plans. The rule had taken effect on 20 July. Which provisions are affected is reported slightly differently by different outlets, so treat the detail as unsettled until CMS responds.

June 2026  ·  2027 open enrollment dates are now unconfirmed

A 2025 CMS rule would have shortened federal marketplace open enrollment to 1 November through 15 December, beginning with plan year 2027, with every plan effective 1 January. A federal court vacated that provision in June 2026, and CMS has published nothing since.

Several consumer sites are still carrying 15 December as the 2027 deadline. Until CMS announces the dates, that is not a fact. Check healthcare.gov directly rather than a secondary source, and if you are relying on the mid-January deadline that existed in earlier years, do not assume it either.

29 May 2026  ·  2027 HSA and HDHP limits published

Rev. Proc. 2026-24 sets the 2027 figures. HSA contributions rise to $4,500 for self-only coverage and $9,000 for a family. To qualify, a plan needs a deductible of at least $1,750 or $3,500, with out-of-pocket maximums no higher than $8,700 or $17,400. The age-55 catch-up stays at $1,000, as it always does: it is set by statute and never indexed.

New this year, and genuinely useful: fee caps for direct primary care service arrangements of $150 a month for an individual and $300 for a multi-individual arrangement. Inside those caps the arrangement is not treated as a health plan, so paying for one no longer disqualifies you from contributing to an HSA.

What the HSA rules actually say

29 January 2026  ·  The ACA out-of-pocket cap jumps 13% for 2027

CMS set the 2027 maximum out-of-pocket limit at $12,000 for self-only coverage and $24,000 for a family, up from $10,600 and $21,200 for 2026. That is the largest single-year rise in this cap since it was introduced, and it applies to non-grandfathered group health plans, not only marketplace plans.

It is a ceiling, not a prediction: it caps how high a plan is permitted to set its own out-of-pocket maximum. But it moves the worst case, and the worst case is what an out-of-pocket maximum is for.

15 January 2026  ·  Poverty guidelines for 2027 marketplace eligibility

HHS published the 2026 federal poverty guidelines: $15,960 for a household of one in the 48 contiguous states and DC, plus $5,680 for each additional person (91 FR 1797). Alaska and Hawaii have their own higher figures.

The timing confuses people every year: the 2026 guidelines govern 2027 coverage, because the marketplace starts using them in November 2026 when it calculates eligibility for next year's plans. Subsidy eligibility for 2026 coverage still runs on the 2025 numbers.

1 January 2026  ·  The enhanced subsidies expired

The expanded premium tax credits introduced in 2021 lapsed at the end of 2025 and were not extended. A three-year extension passed the House in January 2026 and did not clear the Senate; a bipartisan Senate compromise stalled the same month.

The practical effect for anyone buying their own coverage: subsidies revert to the original ACA structure, and the 400% cliff comes back after four years without it. For a household just over the line, that is not a small adjustment.

Expected next

  • 2027 health FSA limit and carryover. The IRS normally publishes these in mid-October.
  • 2027 401(k) deferral and catch-up limits. Normally early November.
  • Confirmed 2027 marketplace open enrollment dates from CMS.

Until each is published we will keep showing the current year's figure and saying so, rather than repeating a projection. Actuarial firms publish forecasts every autumn; those are estimates, not limits, and people plan around them as though they were law.

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