2027 HSA and Health Plan Limits: What Employers Need to Know
Selerix Compliance Corner Update!
The IRS has released Revenue Procedure 2025-32, announcing key cost-of-living adjustments for 2026 that affect several The IRS has released the 2027 inflation-adjusted limits for Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs). The new limits include modest increases to HSA contribution amounts, HDHP deductibles, and out-of-pocket maximums.
In addition, ACA out-of-pocket limits will increase significantly for 2027, and employers sponsoring HSA-qualified plans should review plan designs to ensure continued compliance.
2027 HSA and HDHP Limits
| Limit | 2027 | 2026 | Change |
|---|---|---|---|
| HSA Contribution Limit (employee + employer contributions) | Self-only: $4,500 Family: $9,000 | Self-only: $4,400 Family: $8,750 | Self-only: +$100 Family: +$250 |
| HSA Catch-Up Contribution (age 55+) | $1,000 | $1,000 | No change |
| Minimum HDHP Deductible | Self-only: $1,750 Family: $3,500 | Self-only: $1,700 Family: $3,400 | Self-only: +$50 Family: +$100 |
| Maximum HDHP Out-of-Pocket | Self-only: $8,700 Family: $17,400 | Self-only: $8,500 Family: $17,000 | Self-only: +$200 Family: +$400 |
ACA Out-of-Pocket Limits Also Increase
Separate from HSA and HDHP requirements, the Affordable Care Act (ACA) places annual limits on in-network out-of-pocket costs for non-grandfathered health plans.
| ACA Maximum Out-of-Pocket | 2027 | 2026 | Change |
|---|---|---|---|
| Self-only | $12,000 | $10,600 | +$1,400 |
| Family | $24,000 | $21,200 | +$2,800 |
Important Reminder for Family Coverage
Non-grandfathered group health plans must continue to include an embedded individual out-of-pocket maximum when family coverage exceeds the individual ACA limit.
For 2027, this means:
- A covered individual cannot be required to pay more than $12,000 in out-of-pocket costs, even when enrolled in family coverage.
- Plans with family out-of-pocket maximums above $12,000 must include an embedded individual limit of no more than $12,000.
Direct Primary Care Arrangements and HSA Eligibility
Under the Reconciliation Act (commonly referred to as the One Big Beautiful Bill) and IRS Notice 2026-5, participation in a Direct Primary Care Service Arrangement (DPCSA) does not disqualify an individual from HSA eligibility, provided certain requirements are met.
One key requirement is that the monthly DPCSA fee cannot exceed:
- $150 per month for individual coverage
- $300 per month when covering more than one individual
Although these thresholds are indexed for inflation beginning after December 31, 2026, the IRS confirmed that the limits will remain unchanged for 2027.
What Employers Should Review for 2027
As employers prepare for the 2027 plan year, several plan design considerations deserve attention:
HSA-Qualified Family HDHPs
Family HDHPs cannot include an embedded individual deductible that is lower than the minimum family deductible of $3,500.
HDHP Out-of-Pocket Maximums
To maintain HSA eligibility, HDHP out-of-pocket maximums cannot exceed:
- $8,700 for self-only coverage
- $17,400 for family coverage
Direct Primary Care Arrangements
For months beginning in 2027, DPCSA monthly fees must remain at or below:
- $150 for one individual
- $300 for arrangements covering more than one individual
ACA Compliance Requirements
All non-grandfathered health plans—whether HSA-qualified or not—must limit out-of-pocket spending for any covered individual to $12,000 in 2027.
For example, an HSA-qualified HDHP may have:
- Self-only out-of-pocket maximum: $8,700
- Family out-of-pocket maximum: $17,400
and still satisfy ACA requirements, provided the family tier includes an embedded individual out-of-pocket maximum of no more than $12,000.
Bottom Line
The 2027 updates include modest increases to HSA contribution limits and HDHP thresholds, while ACA out-of-pocket limits see a more substantial jump. Employers should review plan designs, enrollment materials, and participant communications well in advance of the 2027 plan year to ensure both HSA and ACA compliance.
Partner with an ACA expert to ensure these updates do not go missed when reporting season comes. Talk to one of our ACA experts to get started.
Disclaimer: Selerix does not provide legal, regulatory or tax guidance, or advice. If legal advice counsel or representation is needed, the services of a legal professional should be sought. The information in this post is intended to provide a general overview of the topics and services contained herein. Selerix makes no representation or warranty as to the accuracy or completeness of the post and undertakes no obligation to update or revise the post based upon new information or future changes.
